Key takeaways
- →FINTRAC requires most records to be kept for at least 5 years and producible within 30 days of a request — a federal rule that applies regardless of province.
- →Provincial file-retention rules are separate and generally longer — New Brunswick's FCNB sets a 7-year minimum on brokerage records, independent of the federal AML clock.
- →“The file” means more than the signed application — email, texts, and notes connected to the transaction are part of the record, not just the paperwork that made it into the closing package.
- →Where we could not independently verify a specific figure — BC, Saskatchewan, and Quebec's exact ongoing retention periods — we say so rather than guess; confirm those directly with BCFSA, the FCAA, or the AMF.
“How long do I need to keep this?” sounds like a one-answer question. On a Canadian mortgage file, it isn't — a federal anti-money-laundering clock and a provincial file-retention clock run at the same time, triggered differently, and the longer one applies whenever they overlap.
Here's what we could independently verify for each, and where we couldn't confirm a figure directly, we say so rather than state a number we haven't checked.
01 · Why are there two different retention requirements on the same file?
FINTRAC's retention rule exists to support anti-money-laundering enforcement and applies to every reporting entity in the mortgage sector, in every province, the same way. Your provincial regulator's retention rule exists for a different reason — consumer protection and the ability to reconstruct what was disclosed, recommended, and agreed to — and each province sets its own figure.
The two rules are not mutually exclusive, and neither one satisfies the other. The safe approach on every file is to identify both applicable clocks and retain for whichever runs longer.
02 · What does FINTRAC actually require you to keep, and for how long?
FINTRAC's record-keeping guidance for the mortgage sector sets a baseline of at least 5 years for most record types, measured from creation or from the date the record was created if no fixed transaction date applies. That covers:
- →Client information records (name, address, date of birth, and occupation for individuals; name, address, and nature of principal business for entities).
- →Large cash and large virtual currency transaction records, where applicable.
- →Receipt-of-funds records connected to a mortgage on real property.
- →Mortgage loan records — the client's financial capacity, loan terms, and occupation or business details.
- →Copies of any reports actually submitted to FINTRAC, kept for 5 years from the submission date.
The practical requirement that trips people up isn't the 5 years itself — it's that records must be producible within 30 days of a FINTRAC request. A record that technically exists somewhere but takes three weeks to locate doesn't meet the standard in any useful sense.
03 · How does provincial file retention compare, province by province?
This is where the genuinely different rules show up. Here's what we verified directly, and what we couldn't:
| Jurisdiction | What we could verify | Source confidence |
|---|---|---|
| Federal (FINTRAC, all provinces) | At least 5 years; producible within 30 days of a request | Confirmed directly from FINTRAC's published guidance |
| New Brunswick (FCNB) | Minimum 7 years on brokerage records | Confirmed directly from FCNB's published disclosure and compliance guidance |
| Ontario (O. Reg. 188/08) | Retention tied to the life of the transaction rather than a flat figure, commonly cited as roughly 6 years past the transaction's expiry | Corroborated across independent summaries of the regulation's text; we could not open FSRA's own site directly (it blocks automated fetch) to confirm the exact wording ourselves |
| Alberta (RECA) | RECA's published guidance calls for a minimum multi-year retention on mortgage-deal records, extendable if RECA opens an investigation | Corroborated across RECA's own published guidance found via search; our direct attempts to open the specific page returned an error, so treat the exact figure as directional and confirm with RECA |
| BC, Saskatchewan, Quebec | Each regulator sets its own record-keeping rule under the Mortgage Services Act (BC, in force October 13, 2026), the Mortgage Brokerages and Mortgage Administrators Act (Saskatchewan), and the AMF's framework (Quebec) | We could not independently verify a specific ongoing-retention figure for any of the three — confirm directly with BCFSA, the FCAA, or the AMF |
04 · What actually counts as part of the record you have to keep?
“The file” is broader than the documents that made it into the closing package. Email threads, text messages, and internal notes connected to a client relationship or a transaction are part of the record — not just the signed application, the disclosure statement, and the mortgage instrument itself.
This applies even to deals that never closed. A file where a client walked away before signing, or where a deal fell through in underwriting, still generated a record — and a later complaint or inquiry about that file will look for exactly the documentation you might otherwise be tempted to discard.
05 · What does a practical retention system actually look like?
The simplest workable approach: identify the longest applicable clock for a given file type and retain for that period, store electronically so records are reproducible on short notice, and build retention into your file-closing checklist rather than relying on someone remembering years later. Electronic records are acceptable under FINTRAC's rules as long as a paper copy can be produced easily — there's no requirement to keep physical originals indefinitely.
If you're setting this up for the first time, our brokerage file audit checklist and first-year compliance calendar both build retention into a broader routine rather than treating it as a standalone task.
Records that are actually retrievable
Retention built into the workflow, not reconstructed under pressure.
Treadstone's fulfillment associates store and organize file documentation the way a review actually asks for it — dated, complete, and retrievable in minutes, not weeks. See what that looks like on a free call.
06 · What actually happens if you can't produce a record when asked?
A missing or slow-to-locate record is one of the more common findings in a compliance review — not because the underlying file was necessarily handled badly, but because the paper trail wasn't retrievable when someone asked for it. See our companion piece on what a regulator actually asks for in an audit for what that request typically looks like in practice.
Frequently asked questions
This article is general information to help you scale — not a substitute for tailored advice on your specific business, licensing, or compliance obligations. All figures are illustrative examples for planning purposes; actual costs vary by province, market, and brokerage.