BCFSA disclosure forms depend on who you represent in the mortgage transaction. This guide summarizes common dealing scenarios and points you to the official BCFSA resources.

Important: This article is a general reference, not compliance or legal advice. Always follow your brokerage’s compliance policies and the instructions of your Principal Broker or Compliance Officer. If they require a different process or additional documentation, follow those requirements.

Who is your client?

For most residential mortgage files, the borrower is your client. Private lending may involve a lender client or an unrepresented borrower.

I represent the borrower

Typically: Form 1A + Disclosure Package #1

This is the common purchase, refinance or switch/transfer workflow when you arrange financing for your borrower client.

Form 1A confirms and explains borrower representation. Package #1 covers suitability and material risks, remuneration, and interests or conflicts.

QUICK RULE: Borrower is my client → Form 1A + Package #1

BCFSA: Mortgage Services Forms — Form 1A and Package #1

BCFSA: Regulatory Statement — representation and forms packages (ss. 68, 70, 71, 72, 74)

I represent a private lender or MIC

Typically: Form 1B + Disclosure Package #2

Use this when the private lender or MIC is your client and you provide mortgage dealing services on its behalf. Form 1B addresses representation; Package #2 provides the represented-lender transaction disclosures.

Also determine whether the borrower has their own broker. If so, that broker handles their borrower-side disclosures. If not, review scenario 3.

QUICK RULE : Lender is my client → Form 1B + Package #2

BCFSA: Mortgage Services Forms — Form 1B and Package #2

BCFSA: Regulatory Statement — represented-lender package (ss. 68, 70, 71, 73, 75)

I represent the lender, and the borrower is unrepresented

Typically for the borrower: Form 2A + Disclosure Package #3

This can occur where you represent a private lender or MIC and the borrower has no mortgage broker representing them. Form 2A explains the risks of being unrepresented; Package #3 provides the applicable borrower-side disclosures.

In this scenario, both sides may require documentation: lender client → Form 1B + Package #2; unrepresented borrower → Form 2A + Package #3. Check whether any prescribed exception applies to the unrepresented-party disclosure.

QUICK RULE : Borrower is unrepresented → Form 2A + Package #3

BCFSA: Mortgage Services Forms — Form 2A and Package #3

BCFSA: Regulatory Statement — unrepresented-borrower package (ss. 69, 70, 72, 74)

I think I represent both borrower and lender

STOP — conflict / dual-agency review

Do not assume signing both sets of forms makes dual agency permissible. Dual agency is generally prohibited, with limited exceptions. Involve your Principal Broker or Compliance Officer before proceeding.

Where an exception genuinely applies, Form 8 and additional written agreements may be needed. If representation of both clients cannot continue, Form 9 may apply to releasing one or both clients.

QUICK RULE: Both are my clients → STOP + brokerage review

BCFSA: Guideline on Dual Agency

BCFSA: Information on Agency and conflict situations

BCFSA: Disclosures — Conflict of Interest

Quick reference guide

Your situation	Typical form path
I represent the borrower	Form 1A + Package #1
I represent the private lender / MIC	Form 1B + Package #2
Borrower is unrepresented	Form 2A + Package #3
I may represent both sides	STOP → Conflict / dual-agency review

FAQ's

When do the forms happen?

Determine representation before providing dealing mortgage services. The applicable representation or unrepresented-party disclosure comes first; the relevant transaction disclosure package follows when mortgage options are presented, subject to applicable timing rules.

Typical represented-borrower sequence: Form 1A → gather and underwrite → present mortgage option with Package #1 → other applicable disclosures → funding.

BCFSA: Regulatory Statement — disclosure timing and packages

What does Package #1 include?

Part A — suitability, mortgage features and limitations, and material risks. Part B — brokerage and broker remuneration, including applicable fees, commissions and future bonuses. Part C — direct or indirect interests and actual or perceived conflicts.

Package #1 does not replace Form 1A. It also does not replace separate consumer mortgage financial disclosures, including total cost of credit where applicable.

BCFSA: Mortgage Services Forms — Package #1

When in doubt: follow your brokerage’s compliance requirements

This Finmo reference is not a substitute for brokerage policies, compliance review, or legal advice. Your brokerage may impose additional requirements for document timing, signatures, retention, private lending, conflicts, payroll and funding. When unsure, consult your Principal Broker or Compliance Officer before proceeding.