The client
A newcomer buyer bought a $438,000 home in Windsor at 10% down, on $8,600/month of documented income, with no Canadian-issued photo identification yet.
Purchase price
$438,000, Windsor
10% down, insured
Documented income
$8,600/month
Identification on hand
Foreign passport, emailed as a scan
Sent ahead of the appointment; the broker had never viewed the original
Other debt
None carried yet
The problem
FINTRAC's government-issued-photo-identification method requires viewing an original, valid, unexpired document -- in person, or through an accepted non-face-to-face equivalent. An emailed scan received ahead of an appointment satisfies neither: nobody at the brokerage had actually viewed the passport itself.
What an emailed scan doesn't establish
- ▸The scan showed a passport that appeared valid, but nobody had viewed the physical document itself
- ▸A photo taken by the client and sent by email is not, on its own, an accepted identification method
- ▸FINTRAC does allow non-face-to-face verification -- but through a specific, accepted method, not an unverified image
The client's identity was probably exactly what it appeared to be. 'Probably' is not the standard the identification requirement sets.
The numbers
The identification method used had nothing to do with the file's own qualifying math, which cleared easily on its own.
| Qualifying on documented income | Amount |
|---|---|
| Base mortgage (90% of purchase price) | $394,200 |
| CMHC premium (3.10% at 90% LTV) | +$12,220 |
| Total insured mortgage | $406,420 |
| Ratio check at the qualifying rate | Figure |
|---|---|
| Payment at the qualifying rate (6.90%), 25 years | $2,822/mo |
| GDS and TDS alike ($2,822 + $280 tax + $120 heat) ÷ $8,600 income, no other debt carried | 37.5% |
37.5% sits comfortably inside CMHC's 39% GDS and 44% TDS maximums, consistent with the down payment levels shown in down payment statistics for insured, newcomer purchases. The identification question never touched this math at all.
The solution
A mortgage agent licensed under Ontario's Mortgage Brokerages, Lenders and Administrators Act treated the identification method itself as a distinct requirement, separate from whether the client's documents looked genuine.
First, arranged a live video call specifically to view the original passport -- an accepted non-face-to-face identification method under FINTRAC's own rules, and a different thing entirely from an emailed image.
Second, recorded which method was actually used and which document was actually viewed, rather than filing the emailed scan as though it had satisfied the requirement.
Third, completed the know-your-client record only once the original document had actually been seen, not when the scan first arrived.
The outcome
The purchase funded insured at 37.5% GDS and 37.5% TDS, with the client's identity verified by an original document actually viewed, not a copy taken on faith.
Both ratios sit comfortably inside CMHC's 39% GDS and 44% TDS maximums; Ontario's land transfer tax on the $438,000 purchase came to $5,235.
What to take from this file
- 01An emailed scan is not, on its own, an accepted identification method. FINTRAC's government-issued-photo method requires viewing an original document -- confirm which specific method is actually being used before assuming a copy is enough.
- 02FINTRAC does provide non-face-to-face options -- use one of them properly. A live video call viewing the original document is one accepted approach; treat it as a deliberate choice, not an afterthought.
- 03Record the method, not just the outcome. Note which identification method was used and which document was actually viewed, so the file shows how identity was established, not just that it was.
- 04A routine-looking file still needs the identification step done correctly. Strong income and clean documentation elsewhere in the file are not a substitute for verifying identity the way the requirement actually works.
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.
- ▸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.
- ▸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.
Illustrative in this file — lender-specific, not rules:
- ▸4.90% contract rate — rates move daily; not a quote.
- ▸the live video-call identification method — FINTRAC accepts more than one non-face-to-face identification method; a video call viewing the original document is one option, not the only one.
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.