Disclaimer
An order that is made regarding a licence holder reflects a situation at a particular point in time. The status of a licence holder can change. Readers should check the current status of a person’s or entity’s licence on the Licensing Link section of FSRA’s website. Readers may also wish to contact the person or entity directly to get additional information or clarification about the events that resulted in the order.
Financial Services Regulatory Authority of Ontario

IN THE MATTER OF the Mortgage Brokerages, Lenders and Administrators Act, 2006,
S.O. 2006, c.29, as amended (the “Act”), in particular sections 38 and 39;

AND IN THE MATTER OF Lin Liang;

AND IN THE MATTER OF Yujun (Janet) Shi;

AND IN THE MATTER OF Yu (Jade) Wang.


NOTICE OF PROPOSAL TO IMPOSE ADMINISTRATIVE PENALTIES

TO: Lin Liang

AND TO: Yujun (Janet) Shi

AND TO: Yu (Jade) Wang

TAKE NOTICE THAT pursuant to section 39 of the Act, and by delegated authority from the Chief Executive Officer of the Financial Services Regulatory Authority of Ontario (the “Chief Executive Officer”), the Director, Litigation and Enforcement (the “Director”) is proposing to impose forty-four (44) administrative penalties in the total amount of $440,000 on Lin Liang as follows:

  1. Fifteen (15) administrative penalties of $10,000 each, in the total amount of $150,000, for dealing in mortgages for remuneration outside her registered mortgage brokerage, contrary to subsection 2(3) of the Act,
  2. Fifteen (15) administrative penalties of $10,000 each, in the total amount of $150,000, for receiving remuneration from a person or entity other than her registered mortgage brokerage, contrary to subsection 4(1) of Ontario Regulation 187/08,
  3. Fourteen (14) administrative penalties of $10,000 each, in the total amount of $140,000, for doing or omitting to do anything, in circumstances where she ought to have known that she was being used to facilitate dishonesty, fraud, crime or illegal conduct, contrary to section 3.1 of Ontario Regulation 187/08.

AND TAKE NOTICE THAT pursuant to section 39 of the Act, and by delegated authority from the Chief Executive Officer, the Director is proposing to impose twenty-nine (29) administrative penalties in the total amount of $290,000 on Yujun (Janet) Shi as follows:

  1. Ten (10) administrative penalties of $10,000 each, in the total amount of $100,000, for dealing in mortgages for remuneration outside her registered mortgage brokerage, contrary to subsection 2(3) of the Act,
  2. Ten (10) administrative penalties of $10,000 each, in the total amount of $100,000, for receiving remuneration from a person or entity other than her registered mortgage brokerage, contrary to subsection 4(1) of Ontario Regulation 187/08,
  3. Nine (9) administrative penalties of $10,000 each, in the total amount of $90,000, for doing or omitting to do anything, in circumstances where she ought to have known that she was being used to facilitate dishonesty, fraud, crime or illegal conduct, contrary to section 3.1 of Ontario Regulation 187/08.

AND TAKE NOTICE THAT pursuant to section 39 of the Act, and by delegated authority from the Chief Executive Officer, the Director is proposing to impose one (1) administrative penalty in the amount of $10,000 on Yu (Jade) Wang for dealing in mortgages for remuneration while unlicensed, contrary to subsection 2(3) of the Act.

Details of these contraventions and reasons for this proposal are described below. This Notice of Proposal includes allegations that may be considered at a hearing.

SI VOUS DÉSIREZ RECEVOIR CET AVIS EN FRANÇAIS, veuillez nous envoyer votre demande par courriel immédiatement à: contactcentre@fsrao.ca.

YOU ARE ENTITLED TO A HEARING BY THE FINANCIAL SERVICES TRIBUNAL (THE “TRIBUNAL”) PURSUANT TO SECTIONS 39(2) AND 39(5) OF THE ACT. A hearing by the Tribunal about this Notice of Proposal may be requested by completing the enclosed Request for Hearing Form (Form 1) and delivering it to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you. The Request for Hearing Form (Form 1) must be mailed, delivered, faxed or emailed to:

Address:  
Financial Services Tribunal
25 Sheppard Avenue West, 7th Floor Toronto, Ontario
M2N 6S6
Attention: Registrar

Fax: 416-226-7750

Email: contact@fstontario.ca

TAKE NOTICE THAT if you do not deliver a written request for a hearing to the Tribunal within fifteen (15) days after this Notice of Proposal is received by you, orders will be issued as described in this Notice of Proposal. TAKE FURTHER NOTICE of the payment requirements in section 4 of Ontario Regulation 192/08, which states that the penalized person or entity shall pay the penalty no later than thirty (30) days after the person or entity is given notice of the order imposing the penalty, after the matter is finally determined if a hearing is requested or such longer time as may be specified in the order.

For additional copies of the Request for Hearing Form (Form 1), visit the Tribunal’s website at www.fstontario.ca

The hearing before the Tribunal will proceed in accordance with the Rules of Practice and Procedure for Proceedings before the Financial Services Tribunal (“Rules”) made under the authority of the Statutory Powers Procedure Act, R.S.O. 1990, c. S.22, as amended. The Rules are available at the website of the Tribunal: www.fstontario.ca. Alternatively, a copy can be obtained by telephoning the Registrar of the Tribunal at 416-590-7294, or toll free at 1-800-668-0128 extension 7294.

At a hearing, your character, conduct and/or competence may be in issue. You may be furnished with further and or other particulars, including further or other grounds, to support this proposal.

REASONS FOR PROPOSAL

I. INTRODUCTION

  1. The Director is proposing to impose forty-four (44) administrative penalties in the total amount of $440,000 on Lin Liang (“Liang”), twenty-nine (29) administrative penalties in the total amount of $290,000 on Yujun (Janet) Shi (“Shi”), and one (1) administrative penalty of $10,000 on Yu (Jade) Wang (“Wang”).
  2. Liang and Shi dealt in mortgages for remuneration outside the brokerage on whose behalf they were authorized to deal. Liang and Shi accepted remuneration from a person or entity other than their registered brokerage.
  3. Liang and Shi were used to facilitate a mortgage fraud scheme where imposters posed as homeowners to fraudulently obtain mortgage proceeds. The circumstances were such that Liang and Shi ought to have known that by arranging or attempting to arrange the mortgages they were being used to facilitate dishonesty, fraud, or illegal conduct.
  4. Wang dealt in mortgages for remuneration while not licensed under the Act.

II. BACKGROUND

A. Licensees and Others

  1. Liang was licensed as a mortgage agent (licence # M19000939) from April 30, 2019 to March 31, 2022. Liang was terminated by her brokerage (InTrend Mortgage Inc.) on January 24, 2022. Liang’s licence expired on March 31, 2022.
  2. Shi was licensed as a mortgage agent (licence # M15001948) from September 21, 2015 to March 31, 2022. Shi was terminated by her brokerage (The Mortgage Alliance Company of Canada Inc.) on June 3, 2022. Shi’s licence expired on March 31, 2022.
  3. Wang is licensed as a mortgage agent (licence # M15000164) on behalf of the brokerage MoneyBroker Canada Inc. Wang was initially licensed on January 28, 2015. Wang was unlicensed from April 1, 2018 to August 15, 2022. Wang’s licence expired on March 31, 2023 and her renewal application is pending.
  4. Yuansen (Eric) Fu (“Fu”) is wanted by police in connection to an alleged mortgage fraud scheme. Fu has used the aliases “Lucas” and “Ruicong Zong”. Fu is reported to have fled Canada and is believed to be living in China.
  5. ZS/TI Inc., SCG Inc., YS, XH, XX, JSX, JF Ltd., 1BC Ltd., JW, MZ/HG, NY, GC, JS, XH, MC, and YO are private lenders on the below referenced mortgages.

B. The Mortgage Fraud

  1. Fu arranged for imposters to pose as homeowners, using forged and altered documents. Fu and his associates obtained mortgages from private lenders. They retained the mortgage proceeds, leaving the property encumbered. As detailed below, certain transactions brokered by Liang, Shi, and/or Wang formed part of the Fu mortgage fraud scheme.
  2. When the fraudulent mortgages were discovered, they were removed from title. Most lenders and homeowners were made whole by the title insurer. The mortgage fraud was reported by the title insurer that has suffered a significant loss due to the activities described in this Notice of Proposal.

C. Liang

Liang Brokered Mortgages Outside her Brokerage
  1. Between May and November 2021, Liang brokered at least 15 mortgage transactions outside her brokerage and received remuneration from the proceeds outside of the brokerage.
  2. In the course of these transactions, Liang collected documents from the borrower or referral source (often Fu), including identification documents, mortgage statements, condo fee statements, property tax statements, and credit reports. Liang presented the mortgage deal and the borrower’s documents to prospective lenders. If a lender was prepared to lend, Liang provided the mortgage commitment to the borrower and returned the signed commitment to the lender. In some cases, Liang maintained contact with the lender to act as a liaison with the borrower.
  3. Liang brokered mortgages generating proceeds in excess of $17.9 million outside her brokerage.
  4. Liang collected over $1 million in commissions and fees in connection with these transactions. The fees were paid to a corporation owned and controlled by Liang (10350575 Canada Corp.).
  5. Liang did not process these transactions through her registered mortgage brokerage, InTrend Mortgage Inc.
  6. Particulars of the fifteen transactions are summarized in Schedule A, Table 1.
Liang was Used to Facilitate Fraud
  1. In addition to dealing in mortgages outside her brokerage, Liang was used by Fu to facilitate fraud.
  2. Nine of the fifteen mortgage transactions Liang brokered outside of her brokerage were fraudulent in that the borrowers were impersonated. The fraudulent transactions generated proceeds in excess of $13.8 million.
  3. On at least five further occasions, Liang attempted to broker fraudulent transactions, but the prospective lender did not advance funds.
  4. In the circumstances, Liang ought to have known that she was being used to facilitate dishonesty, fraud, crime, or illegal conduct. In particular, the transactions were suspicious because:
    1. A common referral source (Fu) was involved in the transactions;
    2. Liang did not meet with or contact the borrowers directly;
    3. Liang stated that Fu instructed her not to contact the borrowers directly;
    4. For some transactions, the borrower’s name did not match the name on monthly interest cheques;
    5. In one transaction, Liang instructed a lender not to deposit an interest cheque and instead wait for a direct deposit from Fu;
    6. In five transactions, Liang was instructed to arrange a new mortgage to replace an existing mortgage with a significant term remaining (see Schedule A, Table 3). For instance, Liang brokered a mortgage on Stouffville Property 1 approximately two months after the previous mortgage on the property was registered (10 months before the previous mortgage term ended). In addition to significant fees associated with the second transaction related to Stouffville Property 1, the interest for the entire term of the first mortgage had been prepaid from the first mortgage proceeds;
    7. Liang brokered the transactions outside of her mortgage brokerage; and
    8. Liang collected significantly higher fees for the fraudulent transactions as compared to the business she conducted on behalf of her mortgage brokerage.
  5. In addition, Liang misled at least one private lender (ZS/TI Inc.) by telling them that Liang was in direct contact with the borrowers.
  6. The fees collected by Liang for the fraudulent mortgage transactions often exceeded 5% of the mortgage principal. In contrast, Liang collected fees below 1% of principal for mortgage transactions through her mortgage brokerage.
  7. Liang also solicited mortgage lending by JF Ltd. with respect to five properties (Toronto Property 2, Toronto Property 5, Markham Property 1, Stouffville Property 1, and Stouffville Property 2). JF Ltd. declined to lend.
  8. Particulars of the nine fraudulent transactions are summarized in Schedule A, Table 1.

D. Shi

Shi Brokered Mortgages Outside her Brokerage
  1. Between January and June 2021, Shi brokered at least 10 mortgage transactions outside her brokerage and received remuneration from the proceeds outside of the brokerage.
  2. In the course of these transactions, Shi collected documents from the borrower or referral source (often Fu), including identification documents, condo fee statements, and property tax statements. Shi presented the mortgage deal and the borrower’s documents to prospective lenders.
  3. Shi brokered mortgages generating proceeds in excess of $9 million outside her brokerage.
  4. Shi collected $129,483.28 in commissions and fees in connection with these transactions.
  5. Shi did not process these transactions through her registered mortgage brokerage, The Mortgage Alliance Company of Canada Inc.
  6. Particulars of the ten transactions are summarized in Schedule A, Table 2.
Shi was Used to Facilitate Fraud
  1. In addition to acting outside her brokerage, Shi was used by Fu to facilitate fraud.
  2. Nine of the ten mortgage transactions Shi brokered outside of her brokerage were fraudulent in that the borrowers were impersonated. The fraudulent transactions generated proceeds in excess of $8.5 million.
  3. In the circumstances, Shi ought to have known that she was being used to facilitate dishonesty, fraud, crime, or illegal conduct. In particular, the transactions were suspicious because:
    1. Six of the transactions involved the same referral source (Fu). Fu impersonated the homeowner in the seventh transaction;
    2. Shi did not meet with the borrowers directly;
    3. Shi knew that the mortgage proceeds were sent to multiple bank accounts in China not associated with the homeowner;
    4. In at least four transactions, Shi knew that the mortgage proceeds were received by Fu’s mother even though Fu and his mother were not the borrower; and
    5. Shi brokered the transactions outside of her mortgage brokerage.
  4. Particulars of the nine fraudulent transactions are summarized in Schedule A, Table 2.

E. Wang

Wang Dealt in Mortgages while Unlicensed
  1. Together with Liang, Wang brokered the mortgage transaction involving Toronto Property 7 (see Schedule A, Table 1). This mortgage transaction closed on September 14, 2021, when Wang was not licensed under the Act.
  2. Representing the borrower, Liang approached Wang to find a potential lender.
  3. Wang identified JSX as a potential mortgage lender.
  4. Wang represented the prospective lender in the mortgage transaction. Wang received documentation from Liang, on behalf of the borrower. Wang then transmitted the documentation to the prospective lender.
  5. Wang received a fee of $13,000 in relation to the mortgage transaction.
  6. The mortgage transaction was subsequently determined to be fraudulent. This fraudulent transaction generated mortgage proceeds of $3.2 million.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. Statutory Requirements

  1. Subsection 2(3) of the Act prohibits dealing in mortgages in Ontario for remuneration without a licence or an exemption from the requirement to be licensed. Subsection 2(3) also prohibits licensees from dealing in mortgages if they are acting outside their registered mortgage brokerage.
  2. Subsection 4(1) of Ontario Regulation 187/08 prohibits a mortgage agent from receiving any fee or other remuneration for dealing or trading in mortgages from a person or entity other than their registered brokerage.
  3. Section 3.1 of Ontario Regulation 187/08 prohibits a mortgage agent from doing or omitting to do anything, in circumstances where they ought to know that they are being used to facilitate dishonesty, fraud, crime or illegal conduct.

B. Liang

  1. Liang contravened subsection 2(3) of the Act by dealing in mortgages for remuneration outside her registered mortgage brokerage in relation to the fifteen transactions identified in Schedule A, Table 1.
  2. In these fifteen transactions, Liang contravened subsection 4(1) of Ontario Regulation 187/08 by receiving remuneration from a person or entity other than her registered mortgage brokerage.
  3. Liang contravened section 3.1 of Ontario Regulation 187/08 by brokering the nine mortgage transactions identified in Schedule A, Table 1 and attempting to broker five additional mortgage transactions in circumstances where she ought to have known that she was being used to facilitate dishonesty, fraud, crime, or illegal conduct.

C. Shi

  1. Shi contravened subsection 2(3) of the Act by dealing in mortgages for remuneration outside her registered mortgage brokerage in relation to the ten transactions identified in Schedule A, Table 2.
  2. In these ten transactions, Shi contravened subsection 4(1) of Ontario Regulation 187/08 by receiving remuneration from a person or entity other than her registered mortgage brokerage.
  3. Shi contravened section 3.1 of Ontario Regulation 187/08 by brokering 9 mortgage transactions in circumstances where she ought to have known that she was being used to facilitate dishonesty, fraud, crime, or illegal conduct.

D. Wang

  1. Wang contravened subsection 2(3) of the Act by dealing in mortgages for remuneration when not licensed or exempt from the requirement to be licensed on or about September 14, 2021, involving lender JSX.

IV. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

  1. The Director is satisfied that imposing administrative penalties on Liang, Shi, and Wang under section 39 of the Act will satisfy one or both of the following purposes under subsection 38(1) of the Act:
    1. To promote compliance with the requirements established under the Act.
    2. To prevent a person or entity from deriving, directly or indirectly, any economic benefit as a result of contravening or failing to comply with a requirement established under the Act.
  2. The Director is satisfied that forty-four (44) administrative penalties in the total amount of $440,000 should be imposed on Liang for contravening the Act and Ontario Regulation 187/08.
  3. The Director is satisfied that twenty-nine (29) administrative penalties in the total amount of $290,000 should be imposed on Shi for contravening the Act and Ontario Regulation 187/08.
  4. The Director is satisfied that one (1) administrative penalty of $10,000 should be imposed on Wang for contravening the Act.
  5. In determining the amount of the administrative penalties, the Director has considered the following criteria as required by section 3 of Ontario Regulation 192/08:
    1. The degree to which the contravention or failure was intentional, reckless or negligent.
    2. The extent of the harm or potential harm to others resulting from the contravention or failure.
    3. The extent to which the person or entity tried to mitigate any loss or take other remedial action.
    4. The extent to which the person or entity derived or reasonably might have expected to derive, directly or indirectly, any economic benefit from the contravention or failure.
    5. Any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by the person or entity.

Liang

  1. In respect of the first criterion, the Director is satisfied that Liang’s conduct was intentional with respect to acting outside her mortgage brokerage and receiving remuneration from a person or entity other than her brokerage. As a licensee between 2019 and 2022, Liang was aware of her obligation to deal in mortgages solely through her mortgage brokerage and to receive remuneration solely through her mortgage brokerage. Between January and July 2021, Liang processed seven mortgage transactions through her brokerage.
  2. The Director is satisfied that Liang’s conduct was negligent, at best, with respect to her role in facilitating the Fu mortgage fraud. Liang ought to have known she was facilitating a fraud for the reasons set out in paragraph 21 above, including:
    1. The transactions involved a common referral source (Fu);
    2. Liang did not meet with or contact the borrowers directly, at the specific direction of Fu;
    3. For some transactions, the borrower’s name did not match the name on monthly interest cheques;
    4. In multiple transactions, Liang was instructed to arrange a new mortgage to replace an existing mortgage with a significant term remaining (including when interest for the entire term had been prepaid); and
    5. Liang collected significantly higher fees for the fraudulent transactions as compared to the business she conducted on behalf of her mortgage brokerage.
  3. In respect of the second criterion, the Director has considered the significant harm resulting from Liang’s contraventions.
  4. By acting outside the brokerage, Liang deprived her clients of the protections afforded by the Act.
  5. Liang’s role in facilitating the fraud also resulted in significant harm. Although the victims of the fraud were made whole through title insurance, the costs of this type of fraud are passed on to the public in the form of higher title insurance premiums.
  6. The title insurers were harmed by the claims resulting from the fraudulent mortgages that Liang facilitated. Specifically, the title insurers were liable for claims of over $14.2 million due to the fraudulent transactions brokered by Liang.
  7. In respect of the third criterion, the Director is not aware of any action by Liang to try to mitigate any loss or any other remedial action by Liang.
  8. In respect of the fourth criterion, the Director is satisfied that Liang received a significant direct economic benefit from the contraventions consisting of more than $1 million in commissions and fees.
  9. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by Liang.

Shi

  1. In respect of the first criterion, the Director is satisfied that Shi’s conduct was intentional with respect to acting outside her mortgage brokerage and receiving remuneration from a person or entity other than her brokerage. As a licensee between 2015 and 2022, Shi was aware of her obligation to deal in mortgages solely through her mortgage brokerage and to receive remuneration solely through her mortgage brokerage. In June 2021, Shi processed a mortgage transaction through her brokerage.
  2. The Director is satisfied that Shi’s conduct was negligent, at best, with respect to her role in facilitating the Fu mortgage fraud. Shi ought to have known she was facilitating a fraud for the reasons set out in paragraph 34 above, including:
    1. Six of the transactions involved the same referral source (Fu);
    2. Shi did not meet with the borrowers directly;
    3. Shi knew that the mortgage proceeds were sent to multiple bank accounts in China not associated with the homeowner; and
    4. In at least four transactions, Shi knew that the mortgage proceeds were received by Fu’s mother even though Fu and his mother were not the borrower.
  3. In respect of the second criterion, the Director has considered the significant harm resulting from Shi’s contraventions.
  4. By acting outside the brokerage, Shi deprived her clients of the protections afforded by the Act.
  5. Shi’s role in facilitating the fraud also resulted in significant harm. As noted above, the costs of this type of fraud are passed on to the public in the form of higher title insurance premiums and the title insurers were harmed.
  6. In addition, in one transaction brokered by Shi, the lenders did not obtain title insurance. As a result, the lenders (NY and JS) experienced principal losses of $1.1 million. The lenders have initiated a civil claim to attempt to recover these losses.
  7. In respect of the third criterion, the Director is not aware of any action by Shi to try to mitigate any loss or any other remedial action by Shi.
  8. In respect of the fourth criterion, the Director is satisfied that Shi received a significant direct economic benefit from the contraventions consisting of $129,483.28 in commissions and fees.
  9. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by Shi.

Wang

  1. In respect of the first criterion, the Director is satisfied that Wang’s contravention was intentional, or reckless. As a former licensee at the time of the contravention, Wang knew or ought to have known that she was required to be licensed when dealing in mortgages for remuneration.
  2. In respect of the second criterion, the Director is satisfied that Wang’s contravention caused significant harm to the lender.
  3. By acting while unlicensed, Wang deprived the lender of the protections afforded by the Act. Further, her conduct assisted in facilitating Fu’s fraudulent scheme. The proceeds of the fraudulent mortgage that Wang assisted in brokering (alongside Liang) were $3.2 million. The title insurer paid out claims totalling $3,381,622.64 in relation to this transaction.
  4. In respect of the third criterion, the Director is not aware of any action by Wang to try to mitigate any loss or any other remedial action by Wang.
  5. In respect of the fourth criterion, the Director has considered that Wang received a direct economic benefit consisting of $13,000 in commissions and fees related to her contravention.
  6. In respect of the fifth criterion, the Director is not aware of any other contraventions or failures to comply with a requirement established under the Act or with any other financial services legislation of Ontario or of any jurisdiction during the preceding five years by Wang.
  7. Having regarded all the circumstances, including the significant public harm caused and economic benefit gained, the Director is satisfied that the proposed administrative penalties are not punitive in nature, and the amount is consistent with one or both purposes of section 38 of the Act.
  8. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, January 10, 2024

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

SCHEDULE A

Table 1: Liang Mortgage Transactions

Fraudulent Mortgage Transactions Outside the Brokerage
Property Lender Mortgage Amount Liang Fees Fee Percentage Date
1 Toronto Property 1 ZS/TI Inc. $540,000 $18,900.00 3.50% Jul 30, 2021
2 Toronto Property 2 ZS/TI Inc. $1,330,000 $82,509.21 6.20% Oct 4, 2021
3 Toronto Property 3 ZS/TI Inc. $850,000 $57,533.95 6.77% Nov 24, 2021
4 Markham Property 1 ZS/TI Inc. $1,080,000 $73,101.96 6.77% Oct 21, 2021
5 Toronto Property 5 YS, XH $1,870,000 $126,574.69 6.77% Oct 14, 2021
6 Toronto Property 6 SCG Inc., YS $1,800,000 $142,176.60 7.90% Nov 12, 2021
7 Toronto Property 7 JSX $3,200,000 $170,598.40 5.33% Sep 14, 2021
8 Stouffville Property 1 XX $1,700,000 $67,830.00 3.99% Sep 9, 2021
9 Stouffville Property 2 YS, XH $1,500,000 $101,530.50 6.77% Nov 17, 2021
Other Transactions Outside the Brokerage
Property Lender Mortgage Amount Liang Fees Fee Percentage Date
10 Toronto Property 4 ZS/TI Inc. $650,000.00 $6,500.00 1.00% Jul-Sep 2021
11 Markham Property 2 ZS/TI Inc. $850,000.00 $29,750.00 3.50% May 21, 2021
12 Oakville Property 1 ZS/TI Inc. $400,000.00 $8,000.00 2.00% Jul 30, 2021
13 Toronto Property 8 1BC Ltd. $738,514.18 $72,000.00 9.75% Sep 10, 2021
14 Toronto Property 9 MZ/HG $935,912.76 $11,943.75 1.28% Sep 16, 2021
15 Markham Property 3 JW $494,445.67 $74,628.98 15.09% Jul 16, 2021

Table 2: Shi Mortgage Transactions

Fraudulent Mortgage Transactions Outside the Brokerage
Property Lender Mortgage Amount Shi Fees Fee Percentage Date
1. Toronto Property 1 NY $520,000 $7,800.00 1.50% Jan 29, 2021
2. Toronto Property 2 NY, GC, MC $1,100,000 $11,500.00 1.05% Jun 10, 2021
3. Toronto Property 3 YO $750,000 $18,763.56 2.50% Jun 30, 2021
4. Toronto Property 10 GC $425,000 $4,250.00 1.00% May 10, 2021
5. Toronto Property 11 GC $630,000 $7,245.00 1.15% May 27, 2021
6. Markham Property 1 NY, XH $1,000,000 $11,750.00 1.18% May 26, 2021
7. Markham Property 4 NY, JS $1,100,000 $14,000.00 1.27% Apr 13, 2021
8. Stouffville Property 1 YO $1,700,000 $25,337.22 1.49% Jun 30,2021
9. Stouffville Property 2 NY, GC $1,350,000 $20,250.00 1.50% Mar 10, 2021
Other Transactions Outside the Brokerage
Property Lender Mortgage Amount Shi Fees Fee Percentage Date
10. Toronto Property 13 NY $532,500 $8,587.50 1.61% May 12, 2021

Table 3: List of Properties where both Shi and Liang Brokered Mortgages

Property Shi Mortgage Amount Shi Fees Shi Mortgage Date Liang Mortgage Amount Liang Fees Liang Mortgage Date Shi Mortgage Term Remaining
1. Toronto Property 1 $520,000 $7,800.00 Jan 29, 2021 $540,000 $18,900.00 Jul 30, 2021 0 months
2. Toronto Property 2 $1,100,000 $11,500.00 Jun 10, 2021 $1,330,000 $82,509.21 Oct 4, 2021 9 months
3. Toronto Property 3 $750,000 $18,763.56 Jun 30, 2021 $850,000 $57,533.95 Nov 24, 2021 8 months
4. Markham Property 1 $1,000,000 $11,750.00 May 26, 2021 $1,080,000 $73,101.96 Oct 21, 2021 8 months
5. Stouffville Property 1 $1,700,000 $25,337.22 Jun 30,2021 $1,700,000 $67,830.00 Sep 9, 2021 10 months
6. Stouffville Property 2 $1,350,000 $20,250.00 Mar 10, 2021 $1,500,000 $101,530.50 Nov 17, 2021 5 months

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