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 Iqbal Singh Saini, 13016161 Canada Inc. operating as Infinite Mortgage Solutions, Sadik Sadik, and Emerald Lending Group Inc.

NOTICE OF PROPOSAL TO IMPOSE ADMINISTRATIVE PENALTIES

TO:
Iqbal Singh Saini

AND TO:
13016161 Canada Inc., operating as Infinite Mortgage Solutions
06 - 209 Speers Road
Oakville, ON L6K0H5

AND TO: Sadik Sadik

AND TO:
Emerald Lending Group Inc.
1 Severin Street
Brampton, ON L6R 0R1

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 the following administrative penalties in the total amount of $85,000 on Iqbal Singh Saini:

1. $75,000 for dealing in mortgages for remuneration outside of his brokerage, contrary to subsection 2(3) of the Act; and
2. $10,000 for the use of restricted titles, contrary to subsection 11(4) of the Act.

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 an administrative penalty in the amount of $25,000 on 13016161 Canada Inc. operating as Infinite Mortgage Solutions for authorizing an individual to deal or trade in mortgages while it knew or ought to have reasonably known that the individual was authorized by another brokerage, contrary to subsection 43(2) of Ontario Regulation 188/08.

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 an administrative penalty in the amount of $10,000 on Sadik Sadik for failing to take reasonable steps to ensure that the brokerage complies with every requirement established under the Act, contrary to subsection 2(1) of Ontario Regulation 410/07.

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 the following administrative penalties in the total amount of $35,000 on Emerald Lending Group Inc.:

1. $25,000 for carrying on business as a mortgage lender without a license, contrary to subsection 4(2) of the Act; and
2. $10,000 for the use of restricted titles, contrary to subsection 11(2) 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 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. 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. These are reasons for the proposal by the Director to:
   1. Impose two administrative penalties in the total amount of $85,000 on Iqbal Singh Saini (“Saini”);
   2. Impose an administrative penalty in the amount of $25,000 on 13016161 Canada Inc, operating as Infinite Mortgage Solutions (“Infinite”);
   3. Impose an administrative penalty in the amount of $10,000 on Sadik Sadik (“Sadik”); and
   4. Impose two administrative penalties in the total amount of $35,000 on Emerald Lending Group Inc. (“Emerald”).

II. BACKGROUND

A. Parties

2. Saini was previously licensed from June 9, 2015, until March 31, 2023, as a Mortgage Agent Level 1, and from April 1, 2023, to March 31, 2024, as a Mortgage Agent Level 2 under the Act (license #M15001227):
   1. From October 15, 2015, to June 28, 2023, Saini was authorized by The Mortgage Alliance Company of Canada Inc. (“TMACC”); and
   2. From June 29, 2023, to March 31, 2024, Saini was authorized by Infinite.
3. Saini is no longer licensed.
4. Infinite is licensed as a Mortgage Brokerage under the Act (licence #13443). Saini’s mother is a co-owner of Infinite.
5. Sadik was licensed as a Mortgage Agent from June 18, 2008, to March 8, 2020, and has been licensed as a Mortgage Broker from March 9, 2020, to present under the Act (license #M08004987). Sadik is the Principal Broker of Infinite.
6. Emerald has never been licensed under the Act. Saini is the sole director of Emerald.
7. Vault Capital Inc. (“Vault”) is licensed as a Mortgage Brokerage under the Act (licence #13787). Vault also carries on business as a mortgage lender.

B. The Toronto Property

8. In November of 2022, Saini dealt in mortgages for a property located in Toronto (the “Toronto Property”). At that time, Saini was authorized by TMACC.
9. However, Sadik processed this transaction through Infinite and signed the Disclosure to Borrower statement. Infinite received commission of $24,975 for brokering this mortgage. TMACC did not receive any commission and has no record of this transaction.
10. While arranging the mortgage for the Toronto Property, Saini used an email account at Infinite.
11. On these emails, Saini used the email signature “IQBAL SINGH, MORTGAGE BROKER.” Saini has never been licensed as a Mortgage Broker under the Act.
12. To arrange the mortgage for the Toronto Property, Saini solicited lenders (including Vault and an individual lender “AA”), collected the borrower’s information and provided it to the lenders, and arranged for a commitment letter to be issued by Emerald as a lender in respect of the Toronto Property.
13. During the negotiation of the mortgage for the Toronto Property, Emerald held itself out as a mortgage lender. Emerald issued a Commitment Letter to the borrower on Emerald letterhead. Saini collected a $2,000 payment from the borrower pursuant to this Commitment Letter.
14. Prior to funding Saini, on behalf of Emerald, assigned the mortgage on the Toronto Property to Vault.

C. Other Dealings Outside the Brokerage

15. After learning that Saini arranged the Toronto Property mortgage through Infinite, FSRA Investigators contacted Vault and requested a list of transactions that Saini had arranged for them.
16. Vault provided a list of 41 mortgage transactions that Saini arranged in 2021 and 2022. For 33 of these transactions, Saini prepared and signed Disclosure to Borrower documents using TMACC forms. However, of these 33 mortgage transactions, TMACC had records of only eight. The other 25 mortgage transactions that Saini arranged for Vault were processed through Infinite.
17. Saini invoiced approximately $214,000 for arranging these 25 mortgage transactions that were processed through Infinite while he was authorized by TMACC.

D. Emerald’s Use of Restricted Titles

18. Emerald has never been licensed under the Act.
19. In 2022, Emerald identified itself as a “mortgage brokerage” on its website. As a result, on February 15, 2022, FSRA issued a Letter of Warning to Emerald regarding advertising itself as a Mortgage Brokerage.
20. Despite this warning, Emerald subsequently issued fee agreements stating that it was a “Mortgage Brokerage”.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

A. Saini’s Dealing Outside His Authorizing Brokerage

21. Subsection 2(3) of the Act states that “No individual shall deal in mortgages in Ontario for remuneration, whether direct or indirect, as an employee or otherwise, unless he or she has a mortgage broker’s or agent’s licence and is acting on behalf of a mortgage brokerage or is exempted from the requirement to have such a licence.”
22. Supervision by a licensed mortgage brokerage is a cornerstone of the Act and necessary to ensure that borrowers and lenders receive the protections that they are entitled to when entering into a mortgage.
23. The Director is satisfied that Saini contravened subsection 2(3) of the Act by dealing in mortgages for remuneration on behalf of Infinite and not his authorizing mortgage brokerage. In 2021 and 2022, while authorized by TMACC, Saini brokered 25 mortgages for which TMACC has no records. Saini charged commissions of approximately $214,000 for brokering these mortgages.

B. Saini and Emerald’s Use of Restricted Titles

24. Subsection 11(4) of the Act states that “No person or entity shall use in Ontario a description that might reasonably be expected to lead to the belief that he, she or it is a mortgage broker unless he, she or it is licensed as a mortgage broker.”
25. The Director is satisfied that Saini contravened subsection 11(4) of the Act by using the email signature “MORTGAGE BROKER”, when in fact he was licensed as a Mortgage Agent.
26. Subsection 11(2) of the Act states that “No person or entity shall use in Ontario a description that might reasonably be expected to lead to the belief that he, she or it is a mortgage brokerage unless he, she or it is licensed as a mortgage brokerage.”
27. The Director is satisfied that Emerald contravened subsection 11(2) of the Act by issuing fee agreements stating that it was a “Mortgage Brokerage”.

C. Infinite’s Authorization of Brokers, Agents

28. Subsection 43(2) of Ontario Regulation 188/08 states that “A brokerage shall not authorize an individual to deal or trade in mortgages on its behalf if the brokerage knows, or reasonably ought to know, that the individual is a broker or agent who is authorized to deal or trade in mortgages on behalf of another brokerage.”
29. The Director is satisfied that Infinite contravened subsection 188/08 of Ontario Regulation 188/08 by authorizing Saini to deal or trade in mortgages on its behalf in circumstances where Infinite knew or reasonably ought to have known that Saini was authorized to deal or trade in mortgages only on behalf of TMACC.

D. Sadik’s Failure to Take Reasonable Steps to Ensure Compliance

30. Subsection 2(1) of Ontario Regulation 410/07 states “The principal broker of a brokerage shall take reasonable steps to ensure that the brokerage, and each broker and agent authorized to deal or trade in mortgages on its behalf, complies with every requirement established under the Act.”
31. The Director is satisfied that Sadik contravened subsection 2(1) of Ontario Regulation 410/07 by allowing Saini to deal or trade in mortgages on behalf of Infinite despite Saini being authorized by TMACC. Sadik submitted the Toronto Property transaction through Infinite and signed the Disclosure to Borrower statement.

E. Emerald’s Carrying on Business as a Mortgage Lender Without a License

32. Subsection 4(2) of the Act states that “No person or entity shall carry on business as a mortgage lender in Ontario unless he, she or it has a brokerage licence or is exempted from the requirement to have such a licence.” Subsection 4(1) of the Act states that “a person or entity is a mortgage lender in Ontario when he, she or it lends money in Ontario on the security of real property, or holds themself out as doing so.”
33. Emerald issued a Commitment Letter for the Toronto Property to a borrower on Emerald letterhead. The Director is satisfied that Emerald contravened subsection 4(2) of the Act by holding itself out as a mortgage lender, without having a brokerage licence or being exempted from the requirement to have such a licence.

IV. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

34. The Director is satisfied that imposing administrative penalties on Saini, Infinite, Sadik, and Emerald under section 39 of the Act will satisfy one or both of the following purposes under section 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.
35. The Director is satisfied that the following administrative penalties should be imposed:
    1. On Saini:
       1. $75,000 for dealing in mortgages for remuneration outside of his brokerage, contrary to subsection 2(3) of the Act; and
       2. $10,000 for the use of restricted titles, contrary to subsection 11(4) of the Act;
    2. On Infinite, $25,000 for authorizing an individual to deal or trade in mortgages while it knew or ought to have reasonably known that the individual was authorized by another brokerage, contrary to subsection 43(2) of Ontario Regulation 188/08;
    3. On Sadik, $10,000 for failing to take reasonable steps to ensure that Infinite complied with every requirement established under the Act, contrary to subsection 2(1) of Ontario Regulation 410/07; and
    4. On Emerald:
       1. $25,000 for carrying on business as a mortgage lender without a license, contrary to subsection 4(2) of the Act; and
       2. $10,000 for the use of restricted titles, contrary to subsection 11(2) of the Act.
36. 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.
37. In respect of the first criterion, the Director is satisfied that the parties acted intentionally. Saini acted outside his brokerage on at least 26 occasions and repeatedly used restricted titles. Sadik allowed Saini to use an email account at Infinite and identify himself as a Mortgage Broker with knowledge that Saini was authorized by TMACC. Emerald continued to use restricted titles after receiving a Letter of Warning and deliberately held itself out as a mortgage lender without being licensed to do so.
38. In respect of the second criterion, the Director is satisfied that the parties’ activities caused significant harm. By acting outside of his brokerage, Saini undermined the oversight function that brokerages are required to execute within Ontario’s mortgage industry. Brokerages must maintain oversight over agents and remuneration charged in connection with mortgage transactions in order to ensure that borrowers and lenders receive the safeguards they are entitled to and are not charged unauthorized or inappropriate fees. By acting without a license and through Saini but not his brokerage, Emerald also undermined the oversight function provided by licensed brokerages.
39. By authorizing Saini to act, Infinite and Sadik facilitated this harm.
40. Saini and Emerald’s use of restricted titles may have caused the public to believe they were licensed and thus deprived the public of the services of a licensed individual and the protections of the Act and Regulations.
41. In respect of the third criterion, the Director is unaware of any efforts by the parties to mitigate any loss or take other remedial action.
42. In respect of the fourth criterion, as a result of Saini’s failure to comply with the Act he invoiced clients at least $214,000. Saini, Infinite, and Sadik benefited from fees associated with the Toronto Property transaction and other transactions processed through Infinite. Emerald and Saini benefited from receiving business by persons who were deceived by their use of restricted titles.
43. In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Saini, Infinite, Sadik, or Emerald.
44. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, May 22, 2026

Original signed by

Elissa Sinha
Director, Litigation & Enforcement

By delegated authority from the Chief Executive Officer

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