Key takeaways
- →Level 1 agents can arrange mortgages only with financial institutions and CMHC-approved lenders under the National Housing Act; Level 2 adds every other lender type, including private individuals, mortgage investment corporations, and syndicates.
- →To upgrade, you need at least 12 months licensed as a Level 1 agent within the last 24 months, plus FSRA's Private Mortgages Course completed within the two years before you apply.
- →There's no FSRA fee to upgrade from an active Level 1 licence — the only cost is the Private Mortgages Course itself, run by FSRA-approved providers.
- →The two-level structure has applied since April 1, 2023; agents who were licensed before that date were transitioned into the new system automatically.
“Mortgage agent” in Ontario isn't one licence — it's two, and the gap between them is bigger than a title change. A Level 1 agent and a Level 2 agent can be sitting at the same brokerage, doing the same job title, and still be legally restricted to different pools of lenders.
This is what actually changes between the two levels, why FSRA built it this way, and the specific requirements — time-licensed and education — for moving from one to the other.
01 · Why does Ontario license mortgage agents in two levels?
The two-level structure, in effect since April 1, 2023, exists because private lending — mortgages funded by individuals, mortgage investment corporations, and syndicates instead of banks — carries different risks than lending through a federally regulated financial institution. FSRA requires additional, targeted education before an agent can work in that space.
For how this fits into Ontario's broader licensing map, see mortgage licence requirements across Canada.
02 · What can a Level 1 mortgage agent arrange?
A Level 1 agent, working under the supervision of a licensed broker, can deal or trade in mortgages solely with lenders that are financial institutions or lenders approved by CMHC under the National Housing Act. That covers the large majority of conventional bank and monoline lending — it just stops at the private-lender line.
03 · What does a Level 2 licence add?
A Level 2 agent can work with everything a Level 1 agent can, plus “all other mortgage lenders” per FSRA — mortgage investment companies, syndicates, private individuals, and other agents, brokers, or brokerages. Here's the comparison side by side:
| Level 1 | Level 2 | |
|---|---|---|
| Financial institutions / CMHC-approved (NHA) lenders | Yes | Yes |
| Private individuals, MICs, syndicates | No | Yes |
| Minimum licensed time required to hold | None (entry licence) | 12 of last 24 months as Level 1 |
| Extra education required | Mortgage Agent Level 1 course | Private Mortgages Course |
04 · How do you upgrade from Level 1 to Level 2?
Per FSRA's Level 2 requirements, you must have already been licensed as a Level 1 agent for at least 12 months over the last 24 months, and complete an FSRA-approved Private Mortgages Course within the two years before you apply. Approved providers are Mortgage Professionals Canada, the Canadian Mortgage Brokers Association—Ontario, and the Real Estate and Mortgage Institute of Canada, each with a final exam built into the course.
If you hold an active Level 1 licence, FSRA charges no fee to upgrade — you're only paying for the course itself. Your sponsoring brokerage's Principal Broker still has to review and submit the upgrade application through Licensing Link.
Level 2 opens the private-lending door
More lender options mean more files you can actually close.
Whether you're Level 1 or Level 2, Treadstone's fulfillment associates process the files you bring in — so growing your lender access doesn't also mean drowning in paperwork.
05 · When should an agent actually upgrade to Level 2?
The honest answer: whenever a real deal shows up that you can't place without it. Some agents upgrade the moment they're eligible; others wait until a client's file — a self-employed borrower who doesn't fit an A-lender box, say — forces the question. Either way, once you're generating enough Level 1 volume to justify the upgrade, that's often also the point where Treadstone's fulfillment and marketing support starts paying for itself — more file capacity means the Level 2 lender pool is actually usable, not just theoretical.
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.