Simple referral
Contact information only
Paid referral
Disclosure rules apply
Client information
Consent before disclosure
Realtor payment
Subject to brokerage/RECO rules
On this page
Ontario has a specific mortgage 'simple referral' exemption
Ontario Regulation 407/07 allows an unlicensed person or entity to make certain mortgage referrals without holding a mortgage-brokering licence. For a compensated simple referral to a prospective lender, the regulation restricts the borrower information provided to specified contact information and requires written disclosure of the possible fee/remuneration and the relationship involved, plus the borrower's written consent before information is given to the prospective lender.
This boundary matters for Realtors. A referral can become something more than a simple introduction if the Realtor begins collecting detailed financial information, assessing qualification, recommending a mortgage product or transmitting underwriting facts as part of the compensated referral.
RECO financial-benefit disclosure is a separate obligation
RECO Bulletin 3.3 states that a real estate agent must disclose direct and indirect financial benefits the agent or a related person may receive in connection with services to a client, make best efforts to obtain the client's acknowledgement, and follow brokerage rules. RECO also states that agents are prohibited from receiving payment directly from a source other than the brokerage where they are employed.
That means a mortgage referral arrangement should be reviewed at the brokerage level rather than treated as an informal side payment between individuals.
Client consent comes before deal-status sharing too
RECO's confidentiality guidance says confidential client information generally must not be disclosed to third parties without the client's written consent unless authorized or required by law. A mortgage professional likewise should not casually disclose a borrower's credit, income, debt or lender details to a Realtor simply because the Realtor made the introduction.
A cleaner system obtains client consent for milestone-level communication and shares only what is necessary to coordinate the real-estate transaction.
What a clean referral should contain
A simple referral is intentionally simple. The mortgage professional can then collect underwriting information directly from the borrower.
- Borrower's name.
- Borrower's telephone number.
- Borrower's email address.
- Realtor's own contact details so the mortgage team can acknowledge the introduction.
- Confirmation that the client consented to being contacted.
- No tax returns, bank statements, credit details or detailed financial narrative in the referral form.
Refer the mortgage question—do not become the mortgage adviser
RECO has publicly warned against real estate registrants participating in mortgage fraud or asking consumers for money to obtain loan approval. Realtors should not coach clients to alter documents, conceal debts, misstate occupancy or otherwise shape facts to fit financing.
The professional boundary is straightforward: identify the client's need, make the introduction with proper consent/disclosure, provide accurate transaction facts, and let the licensed mortgage professional assess financing.
Use the related tools
Realtor + mortgage coordination
Have a client who needs a mortgage review?
Use the Realtor referral pathway for a consented introduction. Do not upload tax returns, bank statements, credit information or other borrower financial documents through the referral form.
Refer a clientFrequently asked questions
Can an Ontario Realtor receive a mortgage referral fee?
Ontario mortgage law permits compensated simple referrals within the regulatory conditions, while RECO imposes separate financial-benefit and brokerage-payment rules. Any arrangement should be reviewed with the Realtor's brokerage and the mortgage brokerage for current compliance.
Can the Realtor send the mortgage broker the client's income and down-payment details as part of a paid referral?
The simple-referral exemption is deliberately narrow and limits the borrower information transmitted under that exemption to specified contact information. Detailed financial information should be collected directly by the licensed mortgage professional unless another lawful basis and process applies.
Does the client need to consent before the mortgage broker contacts them?
For the compensated simple-referral route to a prospective lender described in Ontario Regulation 407/07, written consent is part of the exemption. Independently, written consent is also a sound privacy and confidentiality practice.
Primary sources
Mortgage, real-estate and new-home rules can change. These resources are educational and do not replace legal advice, your brokerage policies, a lender decision or a property-specific mortgage assessment.