They can't keep up?
CREA would like to see a stable legislative and regulatory environment giving realtors an opportunity to fully understand and comply with the existing obligations without continually having to adjust.
Closing existing loopholes for the real estate sector should be a focus of the government. We are encouraged that the white paper released by the Department of Finance presents the idea of expanding the types of reporting entities that must report to FINTRAC. This would create a more level playing field for real estate; yet, an obvious gap in the law continues to be ignored. Currently, real estate can be sold directly by individuals, which creates a vulnerability where money launderers can conduct real estate transactions without the transparency and examination required when using a realtor. CREA feels that reporting and record keeping obligations should be extended to the companies that facilitate such transactions. While the government is considering extending obligations to other reporting entities, we feel it would be wise to include the for-sale-by-owners companies.
If obligations continue to evolve, education and ongoing outreach efforts are essential for new and existing realtors to make sure that they understand their requirements. We ask that FINTRAC put in place a better outreach strategy to build strong partnerships with reporting entities to maximize compliance. It would also be helpful to clarify existing guidance in a manner that is meaningful to brokers and agents, and adopt policy interpretations that make sense. FINTRAC has the responsibility to try harder to understand that all reporting entities are not the same. A one-size-fits-all model should not be applied across the board. Moreover, when reporting entities ask for policy interpretations and clarifications, responding to the entities' concerns in a timely manner is critical. We feel that greater outreach would have a greater impact in fighting money laundering and terrorist financing for the real estate sector.
We look forward to the committee's report and continuing to help improve the proceeds of crime money laundering and terrorist financing regime.
Thank you for listening.
Mr. Parham and I would be glad to answer any questions the committee members have.