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 Jason A N Singh

NOTICE OF PROPOSAL TO REFUSE TO RENEW LICENCE AND TO IMPOSE ADMINISTRATIVE PENALTIES

TO: Jason A N Singh

TAKE NOTICE THAT pursuant to sections 16 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 refuse to renew the mortgage agent licence issued to Jason A N Singh (licence # M08006764).

AND TAKE NOTICE THAT pursuant to sections 38 and 39 of the Act, and by delegated authority from the Chief Executive Officer, the director is proposing to impose five (5) administrative penalties of $10,000 each, totaling $50,000, on Jason A N Singh for contravening section 43(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 21(2), 21(3), 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 refuse to renew the mortgage agent licence issued to Jason A N Singh (“Singh”) and to impose administrative penalties on Singh.
2. Singh’s past conduct affords reasonable grounds for the belief that Singh is not suitable to be licensed as a mortgage agent. Singh dealt in mortgages outside of his brokerage and attempted to coerce a complainant to drop his complaint with the Financial Services Regulatory Authority of Ontario (“FSRA”) in exchange for receiving repayment of his mortgage loan investment. This behaviour demonstrates that Singh will not deal in mortgages with honesty and integrity or in accordance with the law.
3. Additionally, Singh contravened the Act by providing false or deceptive information or documents when dealing in mortgages in Ontario. Singh did not invest funds in mortgages, contrary to the mortgage loan notes he signed with the investors.

II. BACKGROUND

A. Licensing History

4. Singh is licensed as a mortgage agent (licence # M08006764), under the Act. On March 29, 2026, Singh applied to renew his licence.
5. Singh was first licensed as a mortgage broker on July 1, 2008. Singh became a level 1 agent and is currently authorized to sell on behalf of 11318624 Canada Ltd operating as X Capital Financial.

B. The Complaints

6. In early 2025, FSRA received complaints from RA and SA regarding Singh. RA was seeking mortgage investment opportunities with Singh. RA lent $248,000 to Singh between May 1, 2019 and January 24, 2020, under four “Mortgage Loan Notes”. SA, RA’s father, lent $55,000 to Singh on November 18, 2019, under one “mortgage loan note”.
7. The notes were titled “Mortgage Loan Note” and contained a clause stating that “funds will be invested in properties no less then [sic] 80% LTV”.
8. Proceeds of the loans were paid to companies owned and operated by Singh.
9. The loans are past their maturity. SA and RA received monthly interest initially and until 2024. Singh repaid SA after demand and complaint to FSRA. Singh failed to repay RA, despite demand.
10. Singh stated that the funds were invested in Singh’s business, and not in mortgages. He has been unable to account for RA and SA’s investments or provide evidence that they were invested in mortgages or properties.
11. Singh’s brokerage at the time did not process these transactions and has no record of the SA or RA transactions. Singh did not follow the brokerage’s procedures for soliciting private mortgage investments.

C. Attempted Obstruction of FSRA Investigation

12. After the complaints, Singh contacted RA and SA to arrange for repayment of the loans.
13. In July 2025, Singh demanded that RA withdraw his complaint with FSRA as a condition of repayment.
14. In December 2025 and February 2026, Singh attempted to make complaint withdrawal a term of the settlement agreement he entered with RA to repay the remainder of the loan.

D. False Information on Licence Application

15. In his March 29, 2026, licence renewal application, Singh answered no to the question of whether a complaint had been made against him to a regulatory body based in whole or in part on fraud, theft, deceit, misrepresentation, forgery, or similar conduct.
16. When he submitted his renewal application, Singh was aware of the RA and SA complaints made to FSRA.

III. CONTRAVENTIONS OR FAILURES TO COMPLY WITH THE ACT

17. Section 43(2) of the Act states that no broker or agent shall give, assist in giving or induce or counsel another person or entity to give or assist in giving any false or deceptive information or document when dealing in mortgages in Ontario or trading in mortgages in Ontario.
18. Singh issued documents to SA and RA called “Mortgage Loan Notes” and specifically informed SA and RA that the proceeds of their loans would be invested into properties. Singh’s representations that the loans were secured by mortgages on real property were false and deceptive.
19. All of the funds appear to have been retained by Singh, subject to interest paid out. Singh is unwilling or unable to provide any information about the use of the funds.
20. Section 44(1) of the Act states that no person shall hinder or obstruct the Chief Executive Officer or a person designated by the Chief Executive Officer in the performance of their duties under this Act.
21. FSRA received a complaint and commenced an investigation into Singh’s activities. Singh sought to hinder that investigation by offering repayment if RA withdrew his complaint.
22. Section 45(1) of the Act states that no person or entity shall give false or misleading information to the Chief Executive Officer or a person designated by the Chief Executive Officer in respect of any matter related to this Act or the regulations.
23. Singh gave false or misleading information to the Chief Executive Officer in his 2026 licence renewal application when he answered “no” to the question regarding complaints made against him to a regulatory body. Though FSRA was aware of these complaints, Singh was obligated to answer affirmatively.

IV. GROUNDS FOR REFUSAL TO RENEW LICENCE

24. Section 16(4) of the Act states that the Chief Executive Officer shall renew the licence of an applicant who satisfies the prescribed requirements for renewal of the licence unless the Chief Executive Officer believes, on reasonable grounds, that the applicant is not suitable to be licensed having regard to such circumstances as may be prescribed and such other matters as the Chief Executive Officer considers appropriate.
25. Section 10 of Ontario Regulation 409/07 provides that, in determining whether an individual is not suitable to be licensed as a mortgage broker or agent, the Chief Executive Officer is required by subsections 14(1) and 16(4) of the Act to have regard to the following prescribed circumstances:
    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.
26. Singh has demonstrated a consistent pattern of dishonesty in his dealings with RA and SA, and his statements to FSRA regarding the transactions. RA was seeking investment opportunities in private mortgages. The loan documentation indicates that these funds were to be invested in loans secured by mortgages. These documents contained false and misleading information designed to provide SA and RA with comfort that their investments were secured. Singh cannot account for the funds.
27. Singh also made false statements in his 2026 licence renewal application by answering “no” when asked whether complaints had been made against him to a regulatory body. Singh was aware of the complaints to FSRA.
28. Providing truthful and honest disclosure during the application process is essential to FSRA’s gatekeeping function. FSRA assesses suitability for licensing of applicants to ensure consumers receive competent and ethical mortgage brokering services from licensed mortgage agents. A licence constitutes FSRA’s endorsement to the public and consumers who rely on licensees to understand their options to make informed decisions about important financial matters.
29. Singh’s conduct affords reasonable grounds for the belief that he will not deal or trade in mortgages in accordance with the law and with integrity and honesty.
30. Singh attempted to obstruct the investigation by coercing RA to withdraw the complaint as a condition of receiving repayment of the funds. Accordingly, the Director believes that continuing to licence Singh under the Act will pose a risk to the public interest that cannot be adequately mitigated by attaching terms and conditions to the licence.

V. GROUNDS FOR IMPOSING ADMINISTRATIVE PENALTIES

31. The Director is satisfied that imposing administrative penalties on Singh under subsection 39(1) 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 from deriving, directly or indirectly, any economic benefit as a result of contravening or failing to comply with a requirement established under this Act.
32. In determining the amount of the administrative penalty below, the Director has considered the following criteria as required by subsection 3(1) 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.
33. The Director is satisfied that five administrative penalties of $10,000 each, totaling $50,000, should be imposed on Singh for contravening section 43(2) of the Act by giving false or deceptive information or documents when dealing in mortgages in Ontario. The administrative penalties will prevent Singh from directly benefiting from the contravention.
34. The contraventions of section 43(2) of the Act pre-date February 1, 2022 and are subject to a maximum penalty of $10,000 per contravention.
35. In respect of the first criterion, the Director is satisfied that Singh’s repeated misconduct was intentional. Singh knowingly provided RA and SA with documents which gave them the impression that their funds were to be invested in mortgages. Singh did not invest the funds in mortgages and never intended to do so.
36. In respect of the second criterion, the Director is satisfied that Singh’s misconduct caused serious economic harm to RA and SA. The principal amounts RA loaned Singh for investment in mortgages have not been repaid.
37. Singh’s misconduct as a licensee under the Act also has the potential to harm public confidence in the regulatory regime established by the Act and its regulations.
38. In respect of the third criterion, the Director is unaware of any steps taken by Singh to remedy the contraventions described in this proposal. Singh has attempted to pay back the investments, but the investments are not secured against real property, and RA is still at risk of losing a substantial amount of his investment.
39. Additionally, Singh attempted to hinder or obstruct FSRA’s investigation into his activity, demonstrating that he was not taking any remedial action.
40. In respect of the fourth criterion, the Director is satisfied that Singh derived a direct economic benefit by retaining the mortgage investment funds for his own benefit.
41. In respect of the fifth criterion, the Director is unaware of any further contraventions or failures to comply in the preceding five years by Singh.
42. The Director is satisfied, having considered all the circumstances, that the proposed amount of the penalty is not punitive in nature, and the amount is consistent with one or both purposes of section 38 of the Act.
43. Such further and other reasons as may come to my attention.

DATED at Toronto, Ontario, June 16, 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.