RECO doesn’t inspect a brokerage on a single fixed schedule everyone can plan around. What it does have, published and current, is a growing list of exactly what it wants to see — and now a standing annual filing that asks the broker of record to attest to it in writing.
Key takeaways
A regulator audit stops being a scramble the moment a brokerage treats its ordinary monthly obligations as the audit file, rather than treating audit prep as a separate project that starts when a notice arrives. RECO’s own published guidance points at the same handful of records from three different directions: routine inspections, advertising bulletins, and now a standing annual filing. The statute underneath all three gives RECO real teeth if an audit does turn something up: TRESA lets the Registrar order an administrative penalty of up to $25,000 without a hearing, and a court conviction for an offence under the Act carries a fine of up to $50,000 (or up to two years less a day) for an individual and up to $250,000 for a corporation.
Effective October 1, 2026, RECO’s Annual Financial Filing regime requires every Ontario brokerage to submit financial data — balance sheet items, income statement items, trust account information, financial institution details, trade counts — within “90 days after the brokerage’s fiscal year end date.” The broker of record has to personally attest, in the filing itself, to whether the trust account has been sufficiently funded, whether trust money has been properly segregated, and whether RECO was notified on time of anything that required it. RECO states plainly that the filing “complements” its existing audit and inspection programme and helps it “evaluate risk and target regulatory resources where they are needed most” — in other words, a filing with attestation gaps is itself a signal that can trigger closer attention, not a separate, lower-stakes exercise.
The core of any RECO review of a brokerage’s administration is the same file the brokerage administration resources page already asks the broker of record to maintain: monthly trust account reconciliations, records of every trust deposit and disbursement, and evidence that advertising and trade documentation were monitored, not just produced. A brokerage that runs its monthly RETA reconciliation properly — see reconciling the brokerage trust account for what that reconciliation actually checks — has, by the time an audit or the annual filing comes due, already generated most of what either one asks for.
A shortfall or missing property in the trust account has its own reporting clock, separate from any audit or filing cycle. RECO’s bulletin on the subject requires a brokerage that finds a shortfall to notify RECO immediately and deposit sufficient funds — not disclose it at the next scheduled review, and not wait to see if it resolves itself. An audit or the annual filing is where a brokerage shows its house is in order over time; a shortfall is a same-day problem regardless of when the next review happens to fall.
Advertising compliance has its own review channel: a broker of record or brokerage manager can request RECO run an advertising compliance review before an ad goes public, using RECO’s own review form. See reviewing advertising before publication for how that process works day to day. Registration records — who is currently registered, who transferred in or out and when, and whether post-registration education deadlines were met — are the other file an examiner or the annual filing’s trade-count section will ask a brokerage to produce on request, which is why the onboarding checklist for new registrants treats those dates as something to log at the moment they happen, not reconstruct later.
A RECO audit and a FINTRAC examination are not the same event and don’t run on the same schedule, but a brokerage preparing for one should not ignore the other. FINTRAC’s compliance programme guidance requires the brokerage to review its own programme’s effectiveness at least every two years, on top of maintaining a designated compliance officer, current written policies, a documented risk assessment, and ongoing staff training. If a RECO reviewer or the annual filing surfaces a gap in trust handling, the honest next question is whether the brokerage’s FINTRAC risk assessment ever accounted for that gap — the two regimes examine overlapping conduct from different angles, and a brokerage that only prepares for one leaves the other exposed.
A brokerage’s fiscal year ends December 31, 2026. Its Annual Financial Filing deadline follows directly from the 90-day rule:
The math
fiscal_year_end = Dec 31, 2026filing_due = Dec 31, 2026 + 90 days = Mar 31, 2027
The broker of record now has a fixed date, not a vague “sometime after year-end.” Working backward from March 31, 2027: the December trust reconciliation needs to be complete and reviewed well before the filing window opens, any shortfall found during that reconciliation needs to already be reported and cured — not still open when the attestation is signed — and the trade-count and trust-detail sections need source records pulled from the same monthly files, not rebuilt from memory in the final week.
Move the fiscal year-end to March 31 instead and the filing date shifts to June 29 — the deadline is a function of the brokerage’s own fiscal calendar, not a single date every Ontario brokerage shares. Confirming that one date correctly is the first item on any audit-readiness checklist, because every other deadline in this article is set relative to it.
No. RECO describes the filing as complementary to its existing audit and inspection work, not a replacement for it — the filing is a standing, self-reported attestation; an audit or inspection is RECO examining the brokerage’s own records directly.
The reco.on.ca pages reviewed for this article describe the filing and the bulletin-driven reporting duties in detail but do not publish a specific inspection trigger list; treat any complaint, shortfall report, or filing irregularity as something that can prompt closer review rather than assuming inspections are announced on a fixed schedule. A brokerage that has never been inspected should not read that as evidence it never will be — the annual filing exists precisely so RECO can direct its attention where risk shows up, and a clean filing history is a better defence than an assumption about odds.
The broker of record. RECO’s submission requirements page states the broker of record must attest to compliance across trust account sufficiency, fund segregation and timely notifications, and confirm the information submitted is factual and accurate.
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