Registration - In-house Organization

Subject Matters

• Climate
• Environment
• Financial Institutions
• Housing
• Justice and Law Enforcement
• Privacy and Access to Information
• Taxation and Finance

Subject Matter Details

Legislative Proposal, Bill or Resolution, Policies or Program, Regulation

• To address Canada’s housing crisis, the federal government must work with provincial and municipal governments to implement policies that help to increase the supply of housing. As an example, the Government of Canada should require that infrastructure grants only go to areas that expedite development. Furthermore, the Housing Accelerator Fund as presented by the government should focus on supply initiatives.

Policies or Program

• AIC is supporting OSFI Residential Mortgage Underwriting and Mortgage Insurance Practices and Procedures encouraging Federally Regulated Financial Institutions to employ sound valuation practices to determine the value of collateral used to secure and insure mortgages. AIC has recommended that these same guidelines extend to non-federally regulated institutions or organizations offering mortgage financing to Canadians.
• AIC members must complete appraisal reports and other valuation assignments in accordance with the Canadian Uniform Standards of Professional Appraisal Practice (CUSPAP). Compliance with CUSPAP, in part, requires access to a full range of data on the subject property - including information on sales history. This data has traditionally been in the public domain but access has become limited.
• Canadian consumers require additional education on the full range of fees associated with mortgage financing and refinancing as well as the role of various professionals involved in the transaction. A disclosure of all fees incurred as part of obtaining a loan should be a mandatory requirement for all lending institutions - federally and non-federally regulated – to ensure that Canadians understand the financial commitment involved in what is often the largest investments in their lifetime. This includes the appraisal management fee and the appraisal fee.
• Concerns over money laundering and the use of real estate assets to shield funds from scrutiny have become increasingly more strident in recent months. The AIC is asking the Government of Canada to assume a coordinating role in the development of beneficial ownership registries for real estate assets.
• Downward pressure on appraisal fees and increasing demand for quicker turnaround times, combined with the restrictions on accessing good and reliable data, may ultimately drive professional appraisers away from completing mortgage finance work. This places a much higher risk for lenders and for Canadian consumers.
• Introduce a Home Renovation Tax Credit Program
• Over reliance on Automated Valuation Methodologies (AVMs) poses a significant risk for Canadian consumers, lenders and the financial system. The best option to minimize the lending risk for mortgage properties is to have an on-site appraisal conducted by a third-party appraiser to determine the occupancy, the condition of the property, the neighborhood characteristics, and ultimately, the existence of the property.
• Some flood maps in Canada have not been updated for a number of years, in some cases for decades. The need for accurate flood information is essential to property purchasers, developers, lenders and to those engaged in municipal or land use planning. AIC is asking the Government of Canada to take on a coordinating role in this area.
• The mortgage "stress test" is applied to all Canadians seeking mortgage financing through a Federally Regulated Financial Institution (FRFI). AIC supports the removal of the stress test requirement for individuals seeking to renew their existing mortgage providing that the mortgage is in good standing and that all other terms / conditions remain static. AIC supports the notion that such borrowers should have access to the most competitive terms available.

Communication Techniques

• Written communication
• Oral communication
• Grass-roots communication

Government Institutions

• Bank of Canada
• Canada Mortgage and Housing Corporation (CMHC)
• Employment and Social Development Canada (ESDC)
• Finance Canada (FIN)
• Financial Consumer Agency of Canada (FCAC)
• House of Commons
• Infrastructure Canada (INFC)
• Innovation, Science and Economic Development Canada (ISED)
• Natural Resources Canada (NRCan)
• Office of the Superintendent of Financial Institutions Canada (OSFI)
• Prime Minister's Office (PMO)
• Privy Council Office (PCO)
• Public Services and Procurement Canada (PSPC)
• Senate of Canada
• Statistics Canada (StatCan)

Address:
200 Catherine Street
Suite 403
Ottawa, ON  K2P 2K9
Canada

Telephone number: 613-234-6533  Ext. 222
Fax number: 613-234-7197