The client
He sells enterprise software on a base-plus-commission plan — steady work, but the kind where one big December close or one slow January can swing the year’s T4 by tens of thousands of dollars. That volatility is exactly what makes commission income harder to qualify than a flat salary, and it is exactly what tripped up his first mortgage application in London, on a purchase price that sits well inside the average new mortgage amount across Canada.
Employment
Salaried, base plus commission
Software sales; T4 employee whose income varies meaningfully year to year
Two-year income average
$108,000/yr ($9,000/mo)
Average of the last two T4s and NOAs — base is $40,000, the balance is commission
Debts
Student loan $310 + card minimums $95
Per month; no other reported debts
Purchase
$490,000 detached, London
First-time buyer; property tax $283/mo, lender-standard heat estimate $150/mo
Down payment
$49,000 — 10%
Funded through FHSA savings and a Home Buyers’ Plan withdrawal
Insurance status
Insured file, 90% LTV
Under 20% down, so default insurance applies
The problem
His own bank looked at two years of T4s showing very different numbers and did the conservative thing: it qualified him on base salary plus only the commission he had actually earned so far in the current year, treated as a hard floor against a slower quarter ahead. On paper that looks prudent. In practice it manufactured a decline out of a borrower whose income, averaged properly, easily supported the purchase.
The bank’s year-to-date view
- ▸Income used: $6,167/mo — base plus a partial-year commission estimate, not the full two-year average
- ▸Housing costs: $3,015 P&I at the qualifying rate + $283 property tax + $150 heat = $3,448/mo
- ▸GDS: $3,448 ÷ $6,167 = 55.9% — against CMHC’s 39% maximum. Declined before TDS was even run.
Ontario’s FSRA licensing rules don’t dictate how a lender reads commission income — that’s underwriting policy, and it varies. But the standard practice across CMHC-insured lending, and the one that actually reflects how commission income behaves over time, is a two-year average of total T4 earnings, documented against the matching Notice of Assessment for each year — not a snapshot of whichever months happened to be leanest, a distinction covered in full in how lenders actually average commission income.
The numbers
At 10% down this is an insured file, so GDS 39% and TDS 44% are hard caps set by the insurer, not a lender’s internal comfort setting. The $454,671 total mortgage sits close to what average new mortgage amounts across Canada look like for a first-time buyer.
| Structuring the insured purchase | Amount |
|---|---|
| Purchase price | $490,000 |
| Down payment (10%) | −$49,000 |
| Base mortgage (90% LTV) | $441,000 |
| CMHC premium — 3.10% in the 85.01–90% LTV band, capitalized | +$13,671 |
| Total insured mortgage | $454,671 |
Contract rate — 5-year fixed (illustrative, not a quote): 4.39%. Minimum qualifying rate — greater of contract + 2% and 5.25%: 6.39%. Monthly P&I at the qualifying rate, the figure the ratios actually run on: $3,015. Payments computed the Canadian way — rate compounded semi-annually, paid monthly, 25-year amortization — and rounded to the nearest dollar; ratios computed on the displayed dollar figures and rounded to one decimal.
GDS — two ways to read the same commission income
| GDS calculation | Bank’s YTD view | Two-year T4/NOA average |
|---|---|---|
| Income used | $6,167/mo | $9,000/mo |
| Housing costs (P&I $3,015 + tax $283 + heat $150) | $3,448 | $3,448 |
| GDS vs. the 39% cap | 55.9% ✗ | 38.3% ✓ |
TDS — confirming there’s still room after the debts
| TDS line | Monthly |
|---|---|
| Housing costs (GDS numerator) | $3,448 |
| Student loan | $310 |
| Card minimums | $95 |
| TDS vs. the 44% cap | 42.8% ✓ ($3,853 ÷ $9,000) |
The solution
An FSRA-licensed Ontario mortgage agent re-ran the file the way CMHC-insured lending is actually meant to be qualified.
First, diagnosed the decline as a methodology problem, not an income problem. The bank hadn’t found a reason to doubt him — it had simply chosen the most conservative of several defensible ways to average variable income, and that choice alone manufactured a 55.9% GDS out of a file that, averaged properly, wasn’t close to the ceiling.
Second, rebuilt the income on the standard two-year average. Two full years of T4s, matched to the corresponding Notices of Assessment, established $108,000/yr as the documented, defensible figure — not an estimate, an average of two completed tax years. A short employer letter confirmed the base-plus-commission structure hadn’t changed and that he remained in the same role.
Third, packaged the down payment with its own paper trail. Part of the $49,000 came from FHSA contributions and part from a Home Buyers’ Plan withdrawal against his RRSP — both legitimate first-time-buyer tools, and both need their own statements alongside the usual 90-day history so the insurer sees exactly where the money came from, not just that it arrived.
For a two-year commission average, how the split between base and variable pay gets treated is a lender-by-lender question — some run it exactly this way, some average only the commission portion, some ask for a letter projecting the year ahead, a spread illustrated well in a two-year-average file worked start to funded. This file simply found a lender applying the version that reflects how the income actually behaves over time.
The outcome & the closing math
Approved and funded: insured at 90% LTV, 25-year amortization, first-time buyer. The closing-cash math still had to be right, on top of the $49,000 down payment:
| Cash due at closing (beyond the down payment) | Amount |
|---|---|
| Ontario land transfer tax on $490,000 — marginal brackets | $6,275 |
| First-time-buyer LTT refund (maximum $4,000) | −$4,000 |
| Net Ontario LTT after the refund | $2,275 |
| Ontario RST on the CMHC premium — 8% × $13,671; cannot be added to the loan | $1,094 |
| Legal fees, title insurance & adjustments | varies |
The RST is a cash-only cost even though the premium itself is capitalized into the mortgage — a detail worth flagging early so it isn’t a surprise the week of closing.
What to take from this file
- 01Know which averaging method your lender defaults to before you submit. A year-to-date snapshot and a two-year T4/NOA average can produce wildly different GDS results on the identical file — 55.9% versus 38.3% here. Run both before choosing where the file goes.
- 02Two years of T4s plus matching Notices of Assessment is the standard proof for variable income. It documents an average, not an estimate, which is exactly what a conservative underwriter is looking to see.
- 03Ontario’s first-time-buyer LTT refund has a hard ceiling. The $4,000 maximum fully covers the tax on homes up to roughly $368,000 — above that, as here, it only offsets part of the bill.
- 04RST on the default-insurance premium is cash, always. It cannot be capitalized into the mortgage even though the premium itself can — budget it as a separate line, not folded into the down payment math.
- 05A conservative income read is a policy choice, not a verdict. The second lender didn’t take on more risk; it simply measured the same income differently, and correctly.
Sources
Every regulatory figure in this file traces to one of these primary sources. Client details and anything that varies by lender are illustrative, as flagged below.
- ▸CMHC — Purchase (Mortgage Loan Insurance) — default-insurance premium schedule by LTV band (25-year amortization).
- ▸CMHC — CMHC Home Start — minimum down payment tiers (5%/10%) and the $1.5M insured price cap.
- ▸OSFI — Minimum qualifying rate for uninsured mortgages — the minimum qualifying rate — greater of contract rate + 2% or 5.25%.
- ▸CMHC — CMHC Reviews Underwriting Criteria — GDS 39% / TDS 44% maximums and the 600 credit-score floor for insured files.
- ▸Ontario.ca — Retail Sales Tax: Insurance and Benefits Plans — 8% Ontario RST on default-insurance premiums, cash at closing.
- ▸Ontario.ca — Calculating Land Transfer Tax / Land Transfer Tax Refunds for First-Time Homebuyers — Ontario's marginal land transfer tax brackets and first-time-buyer refund.
- ▸Income Tax Act (Canada), s. 146.6 — FHSA limits: $8,000 per year, $40,000 lifetime.
- ▸Income Tax Act (Canada), s. 146.01 — Home Buyers' Plan: up to $60,000 RRSP withdrawal, 15-year repayment.
- ▸Provincial/territorial mortgage-broker legislation fetched directly (bclaws.gov.bc.ca, legisquebec.gouv.qc.ca, fcaa.gov.sk.ca, web2.gov.mb.ca, nslegislature.ca, assembly.nl.ca) plus FCNB's own site for NB and CanLII's index for PE — see notes for per-province method — provincial mortgage regulators and licence titles.
Illustrative in this file — lender-specific, not rules:
- ▸Two-year commission averaging method — averaging rules and exceptions vary by lender.
- ▸4.39% contract rate — rates move daily; not a quote.
Authority & provenance
How this case file was built
We publish the origin, the verification method and the reviewer for every case file, so you can judge how far to trust it before you rely on it with a client.
Where it comes from
Derived from files handled by Treadstone’s fulfillment desk and from scenarios contributed by partner brokerages. Names, employers, exact amounts and dates are changed so no client or file is identifiable.
Provenance: Composite — a pattern seen repeatedly on fulfilled files, not a single transaction.
What is verified
Every regulatory figure traces to a primary source listed above and was checked against it on the date shown. The arithmetic is recomputed by machine on every rebuild.
Anything that varies by lender is labelled illustrative rather than stated as a rule.
Who reviewed it
Reviewed for Canadian regulatory accuracy before publication, and re-checked whenever a cited rule changes.
Reviewed by: Nicholas Parson, Treadstone Associates — reviews every case file before publication.
This case file is professional reference material for licensed mortgage professionals. It is not advice to a borrower, and it is not a lender commitment. Insurer rules, qualifying rates and provincial taxes change — confirm the current position with the insurer, regulator or lender before you rely on any figure here in a live file.