Humber/Ontario Real Estate Course 4 Exam Practice

What is a mandatory element of a FINTRAC compliance regime for a real estate brokerage?

1. Address transactions over 100 annually

2. Appoint a compliance officer

3. Initial training without renewal

4. Register within three months prior to REBBA

5. Report every transaction to FINTRAC

6. Retain documentation for ten years

The correct answer is: Appoint a compliance officer

A compliance officer is a fundamental requirement of a FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) compliance regime within a real estate brokerage. This role is critical as the compliance officer is responsible for ensuring that the brokerage adheres to the legal obligations set out under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This includes creating, implementing, and maintaining an effective compliance program, conducting risk assessments, and managing training for staff. The compliance officer acts as a point of contact for FINTRAC and other regulatory bodies, ensuring that proper procedures are followed, such as reporting large cash transactions, suspicious activities, and maintaining proper documentation. Without a designated compliance officer, a brokerage would struggle to manage its compliance tasks effectively, potentially leading to serious legal repercussions. Other options may pertain to various aspects of compliance or operational practices but do not reflect the mandatory structural framework necessitated by FINTRAC regulations. For instance, while retaining documentation for a set period is an important part of record-keeping, it is not the sole component of the compliance regime itself. Appointing a compliance officer, however, is specifically mandated as it creates accountability and oversight concerning compliance efforts.