IN THE MATTER OF the Mortgage Brokerages, Lenders and Administrators Act, 2006, S.O. 2006, c.29, as amended (the “Act”), in particular sections 18 and 39;

AND IN THE MATTER OF Kathy Locke and Margaret (Marg) Green

NOTICE OF PROPOSAL TO SUSPEND LICENSES and ISSUE INTERIM ORDER SUSPENDING LICENSES

TO: Kathy Locke

AND TO: Margaret (Marg) Green

TAKE NOTICE THAT pursuant to sections 18 and 21 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 suspend the Mortgage Broker license issued to Kathy Locke.

AND TAKE NOTICE THAT pursuant to sections 18 and 21 of the Act, and by delegated authority from the Chief Executive Officer, the Director is proposing to suspend the Mortgage Broker license issued to Margaret (Marg) Green.

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 21(2) AND 21(3) 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 W, 7^th 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.

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. These are reasons for the proposal by the Director to:
   1. Suspend the Mortgage Broker license issued to Kathy Locke (“Locke”); and
   2. Suspend the Mortgage Broker license issued to Margaret (Marg) Green (“Green”).
2. In addition, the Director is issuing an interim suspension order for the Mortgage Broker licenses issued to Locke and Green.

II. BACKGROUND

A. Parties

3. Locke is licensed as a Mortgage Broker (licence #M08003387) under the Act. She has been licensed since at least July 1, 2008. Her license is scheduled to expire on March 31, 2026.
4. Green is licensed as a Mortgage Broker (licence #M08005448) under the Act. She has been licensed since at least July 1, 2008. Her license is scheduled to expire on March 31, 2026.
5. Concierge Mortgage Group Inc. (“Concierge”) is licensed as a Mortgage Brokerage (license #12179) under the Act.
6. Both Locke and Green are licensed through Concierge.
7. Locke is the Principal Broker of Concierge.
8. Locke and Green are both officers and directors of Concierge.
9. Locke is the sole officer and director of 2504535 Ontario Inc. (“2504535”).

B. The Promissory Notes

10. In January of 2026, Locke contacted FSRA and reported alleged wrongdoing by Green.
11. Locke reported that Green had issued numerous promissory notes to investors (the “Promissory Notes”) and had ceased making the required payments. Locke also reported that many of these Promissory Notes were accompanied by documents indicating that they were backed by mortgage security or by the assignment of mortgage security, but that the purported mortgages had not been registered on title. Locke reported that she had co-signed some Promissory Notes and that funds received were deposited to her personal bank account, Green’s personal bank account, or 2504535’s bank account.
12. FSRA also received complaints from members of the public (the “Complaints”). One of the Complaints alleged that the member of the public had provided $300,000 to Locke, Green, and 2504535 based on their representations that the funds were to be invested in mortgages on specific properties. However, payments in respect of the investment had stopped, and the member of the public had determined that the purported mortgages had not been registered on title. Another of the Complaints alleged that the member of the public had provided funds to Locke and Green purportedly to be invested in multiple private mortgages, but that payments in respect of the purported mortgages had ceased.
13. FSRA Staff conducted an on-site examination of the Burlington office of Concierge pursuant to section 30 of the Act (the “Examination”). As a result of the Examination, and documents and information provided by Locke, FSRA Staff determined that:
    1. There are at least 33 “investors” who loaned a total of approximately $4.9 million to Locke and Green;
    2. Green issued and signed unsecured Promissory Notes;
    3. Locke signed some of these unsecured Promissory Notes;
    4. Green issued and signed Promissory Notes purportedly secured by mortgages on real property;
    5. Locke signed some of these Promissory Notes purportedly secured by mortgages on real property;
    6. Funds received from investors were deposited to Locke or Green’s personal bank accounts or into 2504535’s bank account;
    7. Some of the funds borrowed via Promissory Notes were used to make payments to other investors; and
    8. Title searches do not reflect the representations made by Locke and Green in the Promissory Notes and related documents.
14. Green is unable to respond to FSRA’s inquiries at this time.

III. GROUNDS FOR SUSPENSION OF LICENCE

15. Subsection 18(1) of the Act states that the Chief Executive Officer may, by order, suspend a licence,
    1. If the licensee ceases to satisfy the prescribed requirements for issuance or renewal, as the case any be, of the licence;
    2. If the Chief Executive Officer believes, on reasonable grounds, that the licensee is no longer suitable to be licensed having regard to the circumstances, if any, prescribed for the purposes of subsection 14(1) or 16(4), as the case may be, and such other matters as the Chief Executive Officer considers appropriate;
    3. If the licensee contravenes or fails to comply with a requirement established under this Act; or
    4. If such other circumstances as may be prescribed.
16. Under section 10 of Ontario Regulation 409/07, the Chief Executive Officer must have regard to the following circumstances when determining that a mortgage broker is not suitable to be licensed:
    1. Whether the individual’s past conduct affords reasonable grounds for belief that he or she will not deal or trade in mortgages in accordance with the law and with integrity and honesty.
    2. Whether the individual is carrying on activities that contravene or will contravene the Act or the regulations if he or she is licensed.
    3. Whether the individual has made a false statement or has provided false information to the Chief Executive Officer with respect to the application for the licence.
17. Based on the results of the Examination, the Complaints, and information provided by Locke, the Director believes, on reasonable grounds, that Locke and Green are no longer suitable to be licensed:
    1. Locke and Green have issued documents falsely stating that borrowed funds will be secured by mortgages on real property, contrary to subsection 43(2) of the Act;
    2. Locke and Green have issued documents falsely stating the borrowed funds will be used by parties and for purposes different than who and what they were actually used for; and
    3. By administering the Promissory Notes, purportedly secured by mortgages on real property, Locke and Green are holding themselves out as administering mortgages without being so licensed under the Act, contrary to subsection 5(2) of the Act.
18. Accordingly, Locke and Green are carrying on activities that contravene or will contravene the Act or the regulations if they are licensed.
19. Furthermore, their past conduct affords reasonable grounds for belief that they will not deal or trade in mortgages in accordance with the law and with integrity and honesty.
20. FSRA’s investigation into Locke and Green’s activities, including in relation to the Complaints, is ongoing.
21. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, February 12, 2026

Original signed by

Elissa Sinha
Director, Litigation and Enforcement

By delegated authority from the Chief Executive Officer

Si vous desirez recevoir cet avis en français, veuillez nous envoyer votre demande par courriel immediatement a : contactcentre@fsrao.ca.