IN THE MATTER OF the Mortgage Brokerages, Lenders and Administrators Act, 2006, S.O. 2006, c. 29, as amended (the “Act”), in particular sections 16, 21, 38, and 39;

AND IN THE MATTER OF Satyamkumar Trivedi.

MINUTES OF SETTLEMENT AND UNDERTAKING

PART I – INTRODUCTION

Satyamkumar Trivedi (“Trivedi”) was a licensed mortgage agent under the Act (licence # M17001913). He was first licensed on July 24, 2017.
Trivedi was terminated as an agent by his brokerage, The Mortgage Alliance Company of Canada Inc. (“Mortgage Alliance”) (licence # 10530) on August 14, 2023. Trivedi’s licence expired on March 31, 2024, and he has not re-applied to renew his licence.
On February 4, 2025, the Director, Litigation and Enforcement (the “Director”), by delegated authority from the Chief Executive Officer (“CEO”) of the Financial Services Regulatory Authority of Ontario (“FSRA”), issued a Notice of Proposal in respect of Sasitharan Somasekarampillai (“Soma”) and Trivedi (the “NOP”).
On February 25, 2025, Trivedi requested a hearing before the Financial Services Tribunal (the “Tribunal”) in respect of the NOP.
Trivedi and the Director, by delegated authority from the CEO, (collectively the “Parties”) wish to resolve this matter on consent and without a hearing before the Tribunal.

PART II – AGREED FACTS

Mortgage Administration

Trivedi has never held a brokerage or administrator licence or been exempt from having to hold such licences.

Facilitating

Trivedi approached HP with a mortgage investment opportunity related to the Property (the “Transaction”). This involved lending money in the form of a mortgage on a gas station property (the “Property”) purportedly owned by a corporation of which DS was purportedly a Director (the “Borrower”).
Trivedi was the mortgage agent for HP and Dreamz Holdings Ltd. (“Dreamz”) of which HP was the Director. Trivedi collected various documents about the Borrower and the Property, including financial statements, ownership documents, and corporate documents, from Soma. Trivedi also negotiated the mortgage terms, reviewed the commitment agreement with HP, provided HP with an appraisal report on the Property, and provided HP with the Borrower’s identification.
Trivedi accurately advised HP that he had previously acted as a mortgage agent in relation to the Property. That mortgage was paid out.
However, Trivedi failed to take any steps to independently verify any of the information that he was provided by Soma as HP’s mortgage agent in respect of the Transaction. This included not verifying the appraisal report and the Borrower’s identification, which were falsified.
Trivedi never met with, or dealt with, the Borrower directly. He received all of his information through Soma.
Trivedi also reassured HP that there were no issues of concern regarding DS when HP raised issues about his status as director, officer and shareholder of the Borrower, including the fact that government records had not been updated to reflect his status.
Trivedi did not confirm with Soma that Soma had verified any of the information that Soma provided to him.
Trivedi also failed to consider other red flags, such as the change in directors for the Borrower since the previous mortgage on the same Property, the fact that the previous mortgage on the Property was paid out in an unusually short time or the unusually high broker fees on the transaction.

Dealing in Mortgages Outside the Brokerage and Receiving Renumeration Outside the Brokerage

Trivedi dealt in mortgages and received remuneration outside of Mortgage Alliance on four occasions.
First, Trivedi earned fees on a previous transaction involving the same Property in 2021. Trivedi earned a 10% ($55,000) broker fee on the transaction. Trivedi indicated that he gave half of the fee to another agent but provided no evidence to support this.
Second, Trivedi received a 10% ($65,000) broker fee on the Transaction.
Third, Trivedi arranged mortgage financing for MS Corporation with a private lender. Trivedi received a 2% ($7,000) broker fee on this transaction.
Fourth, Trivedi arranged a mortgage loan for Dreamz for a property in Smith Falls. Trivedi received a total 2.6% ($13,750) broker fee on this transaction.

Trivedi Received Additional Remuneration Outside Mortgage Alliance

Trivedi dealt with four other transactions outside his brokerage. From 2021 to 2022, Trivedi received a total of $66,622 in broker fees across these four transactions, which were not submitted through Mortgage Alliance.

Trivedi Misled FSRA and Concealed Information Relevant to an Inquiry

Trivedi denied receiving any fees in relation to the Transaction on two occasions by email to a FSRA compliance officer.
Trivedi was sent an inquiry letter by email on January 24, 2024. The letter identified the consequences of concealing or providing false, misleading, or incomplete information.
Trivedi was interviewed by FSRA investigators. At the start of the interview, he was reminded that it was an offence to provide false, misleading or incomplete information and of the penalties for doing so. Trivedi denied receiving broker fees on two transactions for the Property or on the MS Corporation or Smith Falls transactions.
In addition, Trivedi denied that his bank records would show any other brokerage fees being received.
Trivedi subsequently admitted that he received fees on the four transactions after being shown trust ledgers and bank records.
Trivedi also indicated that he did not admit to receiving broker fees on the Transaction as he did not want to appear to have been part of the fraud.

Trivedi Acted as a Mortgage Administrator Without Being Licensed

Trivedi administered mortgages on the MS Corporation and Smith Falls properties, even though he was not licensed as a mortgage administrator.
In September 2021, February 2022, and March 2022, Trivedi collected interest payments on the MS Corporation property from the borrower and remitted them to the lender.
In addition, on renewal of the mortgage on the Smith Falls property, Trivedi collected twelve cheques for the monthly interest payments from the borrower. The cheques were made out to the lender.

PART III – NON-COMPLIANCE WITH THE ACT

By engaging in the conduct described above in Part II of these Minutes of Settlement and Undertaking (“Minutes”), Trivedi admits and acknowledges that he breached the Act as follows:
1. facilitating dishonesty, fraud, crime or illegal conduct, contrary to section 3.1 of Ontario Regulation 187/08;
2. dealing outside his brokerage on eight occasions, contrary to section 2(3) of the Act;
3. receiving remuneration outside his brokerage on eight occasions, contrary to section 4(1) of Ontario Regulation 187/08;
4. hindering, concealing information and providing false or misleading information to the CEO on three occasions, contrary to sections 44(1), 44(2) and 45 of the Act; and
5. administering mortgages without a licence on two occasions, contrary to section 5(2) of the Act.

PART IV – TERMS OF SETTLEMENT

Trivedi admits the facts contained in Part II of these Minutes.
As a result of his non-compliance with the Act as outlined in Part III of these Minutes, Trivedi accepts the administrative penalties on him. In particular, Trivedi agrees to pay administrative penalties of $180,000.
Trivedi agrees that he is not suitable to be licenced as a mortgage agent or broker as a result of the facts contained in Part II of these Minutes and his non compliance with the Act as outlined in Part III of the Minutes.
Trivedi acknowledges and agrees that he has been given the opportunity to seek independent legal advice and he has done so (or has waived the right to do so) and is entering into these Minutes voluntarily, understanding the consequences of doing so.
Trivedi acknowledges that these Minutes are an undertaking within the meaning of the Act, and that failure to comply may result in immediate regulatory action including, but not limited to, the issuance of a further Notice of Proposal as may be required or prosecution under the Provincial Offences Act.

(a) Issuance of Order

Trivedi acknowledges that, upon execution of these Minutes by the Parties, the order attached as Schedule “A” to these Minutes (the “Order”) will be issued.

(b) Process for Execution of Settlement

Trivedi acknowledges that these Minutes are not binding on the Director until signed by the Director.
These Minutes may be executed in counterparts, and may be executed and delivered by facsimile or e-mail, and all such counterparts and facsimiles or e-mails, as applicable, shall together constitute one and the same agreement.
Upon receiving an executed copy of these Minutes from FSRA, Trivedi will withdraw his Request for Hearing (Form 1) in respect of the NOP before the Tribunal by completing a Withdrawal/Discontinuance (Form 5) and filing it with the Registrar at the Tribunal within five (5) business days.
Upon confirmation from the Tribunal that the Request for Hearing has been withdrawn and the hearing has been cancelled, the Parties agree that the Director will issue an Order in the form attached as Schedule “A” to these Minutes.
The Parties accept and understand that these Minutes and any rights within the Minutes shall enure to the Parties and to any successors or assigns of the Parties.

(c) Disclosure of Minutes and Order

The Parties will keep the terms of these Minutes and the Order confidential until the Order is issued, except that:
1. The Director shall be permitted to disclose the Minutes and the Order within FSRA; and
2. The Parties shall be permitted to inform the Financial Services Tribunal.
If either of the Parties do not sign these Minutes or the Director does not issue the Order:
1. These Minutes, the Order, and all related discussions and negotiations will be without prejudice to FSRA and Trivedi; and
2. FSRA and Trivedi will each be entitled to all available proceedings, remedies and challenges, including proceeding to a hearing of the allegations contained in the NOP. Any proceedings, remedies and challenges will not be affected by these Minutes, the Order, or any related discussions or negotiations.
Upon issuance of the Order:
1. Trivedi agrees that these Minutes and the Order form part of his administrative record for the purposes of any future licensing decision or as an aggravating factor in respect of a future administrative penalty or prosecution against him or any affiliated entities;
2. Trivedi acknowledges that these Minutes and the Order are public and will be published by FSRA on its public website (or that of its successor) along with a press release that summarizes these Minutes and the Order; and
3. The Parties agree not to make representations to any member of the public or media or in a public forum that are inconsistent with these Minutes or the Order.

(d) Further Proceedings

Whether or not the Order is issued, Trivedi will not use, in any proceeding, these Minutes or the negotiation or process of approval of these Minutes as the basis for any attack on FSRA’s jurisdiction, alleged bias, alleged unfairness, or any other remedies or challenges that may be available.
Upon issuance of the Order:
1. Trivedi waives all rights to a hearing before the Tribunal regarding the NOP;
2. Trivedi waives all rights to a judicial review or appeal of the Order;
3. The Director agrees that FSRA will not initiate further proceedings against Trivedi relating to the facts contained in Part II of these Minutes, except where:
  1. New facts relevant to the facts contained in Part II come to the attention of FSRA that are materially different from those facts contained in Part II of these Minutes;
  2. Trivedi fails to comply with any term in these Minutes or the Order; or
  3. FSRA assesses the suitability for licensing of Trivedi or a related entity; and
4. Trivedi agrees that should he fail to comply with any term in these Minutes or the Order, FSRA is entitled to bring any proceedings available to it.

DATED SEP-16-2025 at East Gwillimbury, Ontario

Original signed by

Satyamkumar Trivedi

DATED SEP 16, 2025 at Toronto, Ontario

Original signed by

Travis Moore 90159K
Name of Witness

DATED September 23, 2025 at Toronto, Ontario.

Original signed by

Elissa Sinha
Director, Litigation and Enforcement
Financial Services Regulatory Authority of Ontario

By delegated authority from the Chief Executive Office

APPENDIX A

IN THE MATTER OF the Mortgage Brokerages, Lenders and Administrators Act, 2006, S.O. 2006, c. 29, as amended (the “Act”), in particular sections 16, 21, 38, and 39;

AND IN THE MATTER OF Satyamkumar Trivedi.

ORDER TO IMPOSE ADMINISTRATIVE PENALTIES

Satyamkumar Trivedi (“Trivedi”) was licensed as a mortgage agent (licence # M17001913) under the Act. Trivedi was licensed as a mortgage agent from July 24, 2017, until March 31, 2024, when his licence expired.

On February 4, 2025, by delegated authority from the Chief Executive Officer of the Financial Services Regulatory Authority of Ontario, the Director, Litigation and Enforcement (the “Director”) issued a Notice of Proposal to impose administrative penalties on Trivedi.

A Request for Hearing (Form 1) dated February 25, 2025, was delivered to the Financial Services Tribunal (the “Tribunal”) in accordance with section 39(5) of the Act respecting the Notice of Proposal.

On [DATE], Trivedi withdrew the Request for Hearing, and, on [DATE], the Tribunal closed its file in respect of this matter. This Order is made pursuant to a settlement entered into by Trivedi and the Director.

ORDER

Twenty-two (22) administrative penalties in the total amount of $180,000 are hereby imposed on Satyamkumar Trivedi for the reasons set out in the Minutes of Settlement and Undertaking.

TAKE NOTICE THAT the Financial Services Regulatory Authority of Ontario will deliver
an invoice to Satyamkumar Trivedi (“Trivedi”) with information as to where and how to pay the administrative penalties. Trivedi must pay the administrative penalties no later than thirty (30) days after the Order is issued unless otherwise agreed with the Financial Services Regulatory Authority of Ontario.

If Trivedi fails to pay the administrative penalties in accordance with the terms of this Order, the Chief Executive Officer may file the Order with the Superior Court of Justice and the Order may be enforced as if it were an order of the court. An administrative penalty that is not paid in accordance with the terms of the Order imposing the penalty is a debt due to the Crown and is enforceable as such.

DATED at Toronto, Ontario.

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

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