FINTRAC's record-keeping rules for the mortgage sector cover several distinct record types, each with its own five-year retention clock: client identification information (name, address, occupation); records of any receipt of funds connected to a mortgage transaction, including the date, amount, payment method, and purpose; large cash transaction records; large virtual currency transaction records, where applicable; mortgage loan records documenting the client's financial capacity and the loan's terms; and copies of every report actually submitted to FINTRAC. Each category is retained for at least five years from the date that specific record was created, or, for submitted reports, from the day the report was filed.
The practical implication is that a five-year-old file isn't safe to purge just because the mortgage itself closed or was paid out long ago — the retention clock runs from when the record was created, not from when the underlying mortgage relationship ended. A brokerage's document-retention policy needs to reflect this explicitly, because a general business instinct to clear out old files after a shorter period can create a genuine compliance gap.
A suspicious transaction report has to be filed once a brokerage, broker, or lender has reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. The bar is reasonable grounds to suspect — not certainty, not even a preponderance of evidence. Waiting to be sure before filing is a common mistake; the obligation is triggered by suspicion, and FINTRAC's own guidance is explicit that some delay is permitted while an internal assessment is completed, but only if that delay has a reasonable explanation. There's no minimum dollar threshold for an STR — a small transaction that looks genuinely suspicious triggers the same obligation as a large one.
The filing standard, “as soon as practicable,” sits deliberately between “immediately” and “as soon as possible” — it acknowledges that reviewing a transaction takes some time, without allowing suspicion to sit unreported indefinitely. Once a report is filed, or even contemplated, the person involved cannot tell the client, directly or indirectly, that a report has been or will be made — this “no tipping off” rule applies regardless of how the relationship with the client might be affected by staying silent.
A large cash transaction report is required whenever a brokerage, administrator, or lender receives $10,000 or more in physical cash from a client — whether in a single payment or as several smaller, linked cash payments that add up to that amount over a short period. This applies to cash specifically: bank drafts, wire transfers, and e-transfers don't trigger this particular report, no matter the amount, because the concern is specifically about physical currency moving outside the traceable banking system.
Two other reports round out the mortgage sector's reporting obligations, though both apply far less often in practice: a terrorist property report, filed whenever a brokerage knows that property in its possession or control belongs to or is controlled by a listed terrorist entity, and large virtual currency transaction reports, for transactions of $10,000 or more in cryptocurrency. Most brokerages will go their entire operating life without filing either of these, but the obligation to report immediately upon the relevant knowledge arising doesn't depend on how common the scenario is.
Because the large cash transaction threshold is a specific dollar figure, breaking a large cash payment into several smaller amounts specifically to stay under $10,000 — a practice known as structuring — is itself a recognized red flag, not a way to avoid the reporting obligation. FINTRAC's guidance treats linked transactions that add up to the reporting threshold within a short period the same as a single transaction that crosses it, which is exactly why the large cash transaction rule references “one or more cash transactions” rather than only a single payment.
For a broker, the practical takeaway is to notice the pattern, not just the individual transaction size — a client making several cash payments just under $10,000 within a short window is a more significant signal than the same client making one larger payment above it, precisely because the pattern itself suggests an intent to avoid detection.
None of this works well as a once-a-year compliance exercise bolted onto an otherwise unrelated file process. The practical way to satisfy the record-keeping rules is to build them into the same intake and file-management habits already covered elsewhere in this curriculum — capturing identification method and details at the point of verification, documenting the source and method of any funds received, and flagging anything unusual in the file notes as it happens rather than trying to reconstruct the reasoning months later if a file is ever reviewed. A file with clear, contemporaneous notes is far easier to defend in a compliance review than one where the broker has to rely on memory to explain a decision made a year earlier.
A client makes three separate cash payments of $4,000 each over two weeks toward closing costs, for a total of $12,000. Does this trigger a large cash transaction report?
The large cash transaction threshold applies to a single payment or several linked cash payments that add up to $10,000 or more within a short period — breaking the total into smaller pieces doesn't avoid the obligation, and this pattern is precisely the kind of structuring FINTRAC's guidance flags as a red flag in its own right. What the cash is being used for within the transaction doesn't change the analysis, and a single $12,000 cash payment would trigger the exact same reporting obligation as the split version — the rule cares about the cash total, not the number of payments.
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