Advocacy and Public Policy

As announced on March 10, 2021 by the Financial Services Regulatory Authority of Ontario (FSRAO), the transfer of regulatory oversight of certain Syndicated Mortgage Investments (SMIs) from FSRAO to the Ontario Securities Commission (OSC) occurred on July 1, 2021.
 
For information on FSRAO’s oversight as of July 1, 2021, please visit: https://www.fsrao.ca/industry/mortgage-brokering/regulatory-framework/guidance/supervision-approach-non-qualified-syndicated-mortgage-investments-permitted-clients-and-legacy-non-qualified-syndicated-mortgage-investments-july-1-2021?utm_source=mc&utm_medium=email&utm_campaign=smireminder
 
You can contact FSRAO at  if you have further questions.

On April 8, 2021, the Office of the Superintendent of Financial Institutions (OSFI) launched consultations on a new mortgage stress test and reiterated the importance of sound collateral management in mortgage underwriting. OSFI sought feedback from stakeholders with a deadline of May 7, 2021.
 
The AIC made a submission which can be viewed here (attached).
  
On May 20, 2021, OSFI announced it was moving forward with the proposed revised stress test for uninsured mortgages (i.e., those with a down payment of greater than 20 percent). Finance Canada also announced it will be applying the same to insured mortgages.
 
Essentially, it meant that as of June 1, 2021, the qualifying rate for uninsured and insured mortgages at Federally Regulated Financial Institutions went from the greater of the mortgage contractual rate plus 2% or the Bank of Canada five-year benchmark rate (which as at 4.79%) to a fixed floor which is the greater than the mortgage contractual rate plus 2% or 5.25%. More information can be found here: https://www.osfi-bsif.gc.ca/eng/osfi-bsif/med/Pages/b20nr-0521.aspx?utm_source=Twitter&utm_medium=smo&utm_campaign=b20&utm_content=nr
 

In June 2022, the House of Commons Standing Committee on Finance invited individuals and organizations to submit their comments for the 2023 Pre-Budget consultation process. The AIC submitted its paper on September 29, 2022, and a copy can be found here:
https://www.aicanada.ca/wp-content/uploads/AIC-Finance-Committee-Pre-Budget-Submission-2023.pdf

The AIC reiterated the need for prudent mortgage underwriting guidelines that include the verification of the collateral being used to secure a loan, the need to focus on housing supply by quickly implementing the Housing Accelerator Fund and the urgency of updating flood maps.

Prior to the federal budget being tabled, the Finance Minister launched Pre-Budget Consultations in January 2022. Click here to view the AIC submission.

The AIC recommendations include the following:

1. Address the Housing Crisis by requiring infrastructure grants to go to areas that expedite and promote sound development practices, such as near transit stations
i. Rapidly deploy the new Housing Accelerator Fund
2. Continue to Apply Prudent Underwriting Guidelines
i. Caution on the over-reliance on Automated Valuation Models
3. Complete improvement of the quality of terrain data, such as flood maps
4. Ensure the proposed Underused Housing Tax is based on appropriate property valuation

n June 2021, and before the federal elections being called, the House of Commons Standing Committee on Finance invited individuals and organizations to submit their comments for the 2022 Pre-Budget consultation process. The AIC submitted its paper on August 6, 2021, and a copy can be found here (attached).

The AIC reiterated the need for prudent mortgage underwriting guidelines that include the verification of the collateral being used to secure a loan, the inherent risks of using Automated Valuation Models and the need to focus on housing supply policies to address housing affordability issues.

If you have any questions for the AIC Advocacy team, please email us at 

The federal government tabled its 2021 Budget on April 19, 2021. It can be viewed here: https://www.budget.gc.ca/2021/pdf/budget-2021-en.pdf

This was a historic one as the Minister of Finance, Chrystia Freeland, was the first woman in Canada’s history to deliver a budget in the House of Commons.

While the 700+ pages document requires some follow up and clarification, here are a few commitments that were noticeable to the real estate industry:

• An annual 1% tax on the value of non-resident, non-Canadian owned residential real estate that is considered to be vacant or underused, effective January 1, 2022.
• In addition to up to $5,000 grants announced in last Fall’s Economic Statement that will be delivered via Natural Resources Canada, provide $4.4 billion to CMHC to help homeowners complete home retrofits through interest-free loans worth up to $40,000. Loans would be available to homeowners and landlords who undertake retrofits identified through an authorized EnerGuide energy assessment. Pre and post-appraisals can be beneficial for many consumers who may be taking advantage of these programs.
• $63.8 million over three years to Natural Resources Canada, Environment and Climate Change Canada, and Public Safety Canada to work with provinces and territories to complete flood maps for higher-risk areas. The need for updated flood maps in Canada was one of AIC’s pre-pandemic recommendations as appraisers can help identify these risks to their clients with the proper data and we are encouraged to see that the federal government has committed funding towards this initiative.  
• Additional funding for affordable housing such as $1.5 billion for the rapid Housing Initiative, $600 million to renew and expand the Affordable Housing Innovation Fund and $315.4 million over seven years to increase payments through the Canada Housing Benefit.

Many were of the mind that the budget was going to have measures to address the overheated residential market, however, at first glance, it seems that the federal government has decided not to weigh in in any significant way – for the time being.

We will follow up and provide feedback on these different measures as they get implemented.

The Federal Finance Minister launched Pre-Budget Consultations in January 2021. We asked Members to provide their comments to us via the February 2021 communique as we prepared our submission. Click here to view the submission.

The Federal Finance Minister launched Pre-Budget Consultations in January 2021. We asked Members to provide their comments to us via the February 2021 communique as we prepared our submission. Click here to view the submission.

For any questions or comments, please don’t hesitate to contact us at 

AIC 2021 Pre-Budget Submission to House of Commons Finance Committee

In June 2020, the House of Commons Standing Committee on Finance invited individuals and organizations to submit their comments for the 2021 Pre-Budget consultation process. The AIC submitted its paper on August 7, 2020, and a copy can be found here.

If you have any questions for the AIC Advocacy team, please email us at 

Over the last several weeks, the House of Commons Finance Committee has been hearing testimony from organizations, associations and individuals from across the country in terms of how the federal government has responded to the COVID-19 Public Health Crisis.

As the AIC often does, we took this opportunity to make a submission to the Committee to inform them of what AIC members have done to adapt to the current realties all while continuing to meet the needs of Canadians. It also speaks to how important valuation fundamentals are, especially with such market uncertainty and volatility.

The submission can be viewed here.

Questions or comments? Please send them to 

Appraisals in a New Market with Dan Brewer
(AACI, P.App, Fellow)

(Watch it here)

Listen here on Spotify or Podbean 

Members may recall that from November 25 to December 3, 2021, the Appraisal Institute of Canada’s Advocacy Committee, as well as Members of the AIC’s Executive and Communications Committees, met with nearly 20 Members of Parliament (MP) as part of the AIC’s Virtual Parliament Hill Days. While in previous years these meetings occurred in person in Ottawa, the latest iteration occurred virtually due to the ongoing uncertainties around the COVID-19 pandemic.

Following those meetings, the AIC Leadership continued to engage with Federal Members of Parliament and officials. Here is a list of meetings that have occurred since the Virtual Hill Days:

• Finance Committee Member, Yvan Baker
• Office of Member of Parliament, Michelle Rempel
• Senior Finance Canada Department Officials
• CMHC Senior Officials
• Finance Committee Member and NDP Finance Critic, Daniel Blaikie
• Prime Minister’s Advisor on Housing
• Finance Committee Member and Conservative Associate Shadow Minister of Finance and Housing Inflation
• Parliamentary Secretary to the Minister of Housing and Diversity and Inclusion (Housing), Soraya Martinez Ferrada

AIC is continuing its efforts to get in front of federal legislators to ensure appraisers are included in discussions related to real estate as well as to create relationships that could be beneficial for AIC Members and the protection of the public.

The new OSFI Canada Superintendent – Peter Routledge met with AIC President André Pouliot and AIC CEO Keith Lancastle in October. There was a lot of open and frank discussion about the housing market and the important role of appraisers. Both the AIC and OSFI agreed to keep the lines of communication open and discuss matters of mutual interest.

Looking forward to the continued collaboration between these two agencies.

With the federal election campaign well underway, we have launched a digital grassroots campaign to ensure that appraisers are continuously consulted when housing policies and decisions are made.

On the Members’ portal of the Aicanada.ca website, you will find a digital advocacy tool that will let you send a template letter to your local federal election candidates. All you need to do is fill out your address and name, and click send – the personalized letter will automatically be sent to your candidates.

By participating in this campaign, we can ensure that all future Members of Parliament know the importance of the AIC Designated Appraisers and your role in the communities that you work in.

On that page, you’ll also find a summary of the major parties’ policy positions on housing issues, as well as the AIC policy recommendations that align with the respective party policy positions.

Access the tool here.

If you have any questions, please contact the AIC Advocacy Team at 

In early 2021, the Federal Government launched consultations on a National Infrastructure Assessment. An engagement paper can be found here: https://www.infrastructure.gc.ca/alt-format/pdf/nia-eni/nia-eni-doc-eng.pdf

The AIC made a submission prior to the June 30, 2021 deadline which can be read here.

On July 14, 2021, the AIC President, André Pouliot, AACI, P.App, met with the Federal Shadow Minister for Housing, Member of Parliament Brad Vis. While the AIC hast met MP Vis in the past, this was an opportunity to reconnect on housing related issues. As the hot housing market continues to be a focus on Parliament Hill, the AIC continues to build relationships with federal officials to provide an overview of the AIC, the important role appraisers play in the real estate market and how our Members have been able to adapt to the realities of COVID-19.

It was also an opportunity to discuss the real estate market and the importance of ensuring that appropriate valuation fundamentals continue to be strengthened and applied to help mitigate risk in the housing market and to protect the public – and the best way to do that is by having an on-site appraisal carried out by qualified, designated professionals. We also communicated that the over reliance on Automated Valuation Models is a risk to Canadians and to the housing market as a whole. Finally, we communicated the importance of focusing on the supply side of the housing equilibrium to tackle the high priced market as opposed to the demand side that has seen its share of changes over the last several years.

Meetings with federal officials will continue over the summer and into the fall.

In mid-May, the AIC had an opportunity to meet with the new President and CEO of the Canada Mortgage and Housing Corporation (CMHC), Ms. Romy Bowers. It was an opportunity to meet with Ms. Bowers early in her tenure to discuss housing-related issues and the important role appraisers play in the real estate market. We look forward to working with Ms. Bowers and her team.

The AIC Advocacy Team was able to have the Conservative Shadow Minister for Housing, as well as the NDP Housing Critic, provide remarks to the AIC Conference attendees.

Remarks by MP Jenny Kwan can be viewed here: https://vimeo.com/726774947/c021ab44e1

On May 12, 2022, AIC President (now Past-President), Andre Pouliot, and former AIC Chief Executive Officer, Keith Lancastle, appeared before the House of Commons Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities to provide input on the federal governments Housing Accelerator Fund and Federal Lands Initiative. Their appearance was made at the request of the Committee.

Their opening statement can be viewed here at 16:34: https://lnkd.in/ef2VAuJS

From November 25 to December 3, 2021, the Appraisal Institute of Canada’s Advocacy Committee, as well as Members of the AIC’s Executive and Communications Committees, met with nearly 20 Members of Parliament (MP). While in previous years these meetings occurred in person in Ottawa on Parliament Hill, this year’s meetings occurred virtually due to the ongoing certainties around the COVID-19 Pandemic.

AIC Members from the above-mentioned committees were able to meet with MPs to introduce AIC and the important role appraisers play in the real estate industry and the Canadian economy. We were also able to advance three housing-related issues and recommendations:

1. The need for ongoing prudent underwriting guidelines that include proper verification of the collateral being used to advance a loan and being cautious of the over-reliance on automated valuation models.
2. The need for the federal government to focus on housing supply initiatives to make housing more affordable.
3. The need for the federal government to continue their efforts on updating floods maps. Floods are just one example of climate risk – issues like drought, severe storms and wildfires can all play a role in the value of a property. The government will need to take a leading role in ensuring information on these risks is widely and consistently available going forward.

It also proved to be an excellent platform to get in front of federal legislators to ensure appraisers are included in discussions related to real estate as well as to create relationships that could be beneficial for AIC Members and the protection of the public.

We will continue to have meetings with MPs and federal officials in the new year as we continue to foster relationships.

To view pictures from some of the meetings that occurred, please visit our Twitter page, Linkedin page or Facebook page.

From November 25 to December 3, 2021, the Appraisal Institute of Canada’s Advocacy Committee, as well as Members of the AIC’s Executive and Communications Committees, met with nearly 20 Members of Parliament (MP). While in previous years these meetings occurred in person in Ottawa on Parliament Hill, this year’s meetings occurred virtually due to the ongoing certainties around the COVID-19 Pandemic.

AIC Members from the above-mentioned committees were able to meet with MPs to introduce AIC and the important role appraisers play in the real estate industry and the Canadian economy. We were also able to advance three housing-related issues and recommendations:

1. The need for ongoing prudent underwriting guidelines that include proper verification of the collateral being used to advance a loan and being cautious of the over-reliance on automated valuation models.
2. The need for the federal government to focus on housing supply initiatives to make housing more affordable.
3. The need for the federal government to continue their efforts on updating floods maps. Floods are just one example of climate risk – issues like drought, severe storms and wildfires can all play a role in the value of a property. The government will need to take a leading role in ensuring information on these risks is widely and consistently available going forward.

It also proved to be an excellent platform to get in front of federal legislators to ensure appraisers are included in discussions related to real estate as well as to create relationships that could be beneficial for AIC Members and the protection of the public.

We will continue to have meetings with MPs and federal officials in the new year as we continue to foster relationships.

To view pictures from some of the meetings that occurred, please visit our Twitter page, Linkedin page or Facebook page.

As always, you can send your feedback or comments to 

As part of the launch of Financial Literacy Month on November 2, 2020, the Financial Consumer Agency of Canada (FCAC) announced they were launching consultations to review and update the National Strategy for Financial Literacy.

They were seeking input from individuals and stakeholders and the AIC made a submission as part of this consultation.

For more information on the FCAC process, please visit: https://letstalkfinancialliteracy.ca/renewing-the-national-strategy-for-financial-literacy

To view the AIC submission, please click here.

As part of this years AIC Annual General Meeting (virtual), the advocacy team invited Federal Minister of Families, Children and Social Development and Minister responsible for the Canada Mortgage and Housing Corporation, the Honourable Ahmed Hussen, to say a few words to AIC members. In case you weren’t able to watch the AGM, here is the Minister’s message to members.

https://vimeo.com/432620346

On February 27, 2020 the Appraisal Institute of Canada’s advocacy committee representatives from across the country met with nearly 25 Members of Parliament and federal government officials on Parliament Hill in Ottawa.

This was another great opportunity for AIC Members to meet with MPs to introduce AIC and the important role appraisers play in the real estate industry and in the Canadian economy.

It also proved to be an excellent platform to get in front of federal legislators to ensure appraisers are included in discussions related to real estate as well as to create relationships that could be beneficial for AIC Members and the protection of the public.

Our 2020 federal pre-budget submission was also a point of discussion – it can be viewed here.

Finally, the full day of meetings was preceded by a roundtable discussion with the Parliamentary Secretary to the Minister of Finance and the Minister of Middle Class Prosperity, Sean Fraser, which resulted in a good and in depth policy discussion on housing in Canada.

To view pictures from some of the meetings that occurred, please visit our Twitter page @AIC_Canada or Facebook page.

As always, you can send your feedback or comments to 

In mid-December, the Federal Government released their ministerial mandate letters (can be read here).

As you may recall, the AIC’s recommendations to political parties heading into and throughout the last federal election were the following:

– Updating flood maps across Canada

– Exempting Mortgage Renewals from the Application of the Stress Test under B20 Guidelines

– Combatting Money Laundering Through a Beneficial Ownership Registry

Upon review of the ministerial mandate letters, we are pleased to see that the government has made all three of the recommendations priorities for government ministers:

• Innovation Minister: Work with the Minister of Finance and interested provinces and territories and communities to establish a national approach to beneficial ownership so that law enforcement and the Canada Revenue Agency have the tools to crack down on financial crime in real estate while respecting Canadians’ privacy rights. With the support of the Minister of Finance, conclude consultations with the provinces and territories on the creation of a pan-Canadian public registry for beneficial ownership and prepare legislation reflecting the outcome of those consultations.
• Natural Resources Minister: Work with the Minister of Public Safety and Emergency Preparedness and with the provinces and territories and Indigenous Peoples to complete all flood maps in Canada.
• Finance Minister: Review and consider recommendations from financial agencies related to making the borrower stress test more dynamic.

With the Advocacy Committee meeting in late February 2020 in Ottawa, we will meet with Members of Parliament from all political stripes to reiterate the above mentioned public policy priorities and continue to articulate the importance that progress be made on these files.

For questions or comments on this or any other advocacy related matter, please contact us at 

Last spring, the federal government launched consultations on a beneficial ownership registry.
 
The AIC made a submission arguing that the federal government should work with provinces and territories to create a publicly accessible registry of beneficial ownership to help address money laundering in the real estate market. We also argue that this registry and other real estate-related data such as property and land title registries should be accessible to professional appraisers and other real estate professionals to ensure reliable, consistent and comprehensive data when determining the value of real property.
 
The federal departments responsible for this consultation, Innovation, Science and Economic Development Canada and Finance Canada, recently published what they heard in the following document: https://www.ic.gc.ca/eic/site/142.nsf/eng/00002.html

In June 2020, the Government of Alberta tabled and passed amendments to the Real Estate Act in the Alberta Legislature that resulted in Real Estate Appraisers no longer requiring to be licensed under the Real Estate Council of Alberta (RECA).
 
As expressed during the consultation process leading up to the Bill being tabled, the AIC and AIC-Alberta welcome these changes as there were limited discernible benefits to the public by being regulated by RECA, and we continue to believe that the AIC’s self-regulation processes and other measures adequately regulate its members and protect the public.
 
The amendments to the Act came into force on December 1, 2020 – meaning that as of that date, Real Estate Appraisers no longer require licensing under RECA.
 
If you have any questions about this, do not hesitate to reach out to RECA at , or AIC at .
 

The Financial Services Regulatory Authority of Ontario (FSRA) has published its proposed 2021-22 Statement of Priorities and Budget for public consultation.

FSRA is inviting the general public and all stakeholders to review and provide feedback on the proposed 2021-22 Statement of Priorities and Budget.

The consultation period will close on November 3, 2020.

More information can be found here: https://www.fsrao.ca/engagement-and-consultations/fsra-proposed-2021-22-statement-priorities

In June 2020, the Government of Alberta tabled and passed amendments to the Real Estate Act in the Alberta Legislature that will result in Real Estate Appraisers no longer be required to be licensed under the Real Estate Council of Alberta (RECA). Details of the announcements can viewed by clicking here.

As expressed during the consultation process leading up to the Bill being tabled, the AIC and AIC-Alberta welcome these changes as there were limited discernible benefits to the public by being regulated by RECA, and we continue to believe that the AICs self-regulation processes and other measures adequately regulate its members and protect the public.

While the amendments have been passed in the legislature, licensing and regulation by RECA remains in effect until a “coming into force/proclamation date” that has yet to be announced.

To accommodate the transition away from regulation under the Real Estate Act, RECA has worked with the AIC-Alberta Association to balance the incoming reality with the legislated responsibilities RECA retains until Bill 20 comes into force. The agreed upon solutions are outlined below.

No Fee for License Renewals in 2020

Every year, appraisers renew their license with RECA by September 30. In light of Bill 20 possibly coming into force after the renewal deadline, RECA has agreed to waive the license renewal fee for appraisers for the 2020-2021 licensing year. These licenses will cease upon the proclamation of Bill 20.

Since RECA must continue to regulate appraisers from October 1, 2020 until Bill 20 comes into force, appraisers must still complete a renewal application through myRECA to continue working. It will simply be at no cost.

Waived Pre-Licensing Requirements for New Real Estate Appraisers

Currently, potential real estate appraisers are required to complete RECA’s pre-licensing education focused on professional obligations under the Real Estate Act. These obligations will no longer be relevant upon the proclamation of Bill 20, so the RECA Executive Director has waived the requirement to complete RECA’s pre-licensing education for appraisers prior to becoming licensed.

Potential appraisers who have completed the AIC and AIC-Alberta’s requirements, and who are currently taking or yet to enroll in RECA’s pre-licensing education, can apply for a license immediately, without completing RECA’s course. This license will be for the remainder of the 2019-2020 licensing year, ending September 30, 2020, and is reduced to $275. RECA will not be providing refunds to any potential appraisers who have begun the course.

AIC-Alberta and RECA agree that potential appraisers should continue to read the Real Estate Act and Rules, and combined with responsible supervising real estate appraisers, this will provide adequate oversight for new appraisers in the interim.

If you have any questions about this transition, do not hesitate to reach out to RECA at , or AIC at .

While the COVID-19 pandemic has consumed most of AIC-BC’s time and resources, work continues on the advocacy front in several areas. One of the areas of focus has been making submissions to the Government of BC related to ongoing consultations on the Public Beneficial Ownership Registry, the Mortgage Brokers Act, and the future of housing supply and affordability.

AIC-BC made submissions for all three over the course of the last two months and they can be viewed here:

• Public Beneficial Ownership Registry 
• Mortgage Brokers Act
• Future of housing supply and affordability

For more information or comments, contact AIC-BC at 

For information and comments for AIC-National, please contact 

The Appraisal Institute of Canada – Quebec Association, in collaboration with the Ordre des évaluateurs agreés du Québec (OEAQ), the Urban development institute of Quebec (UDI), the Canadian Property Tax Association (ACTF), the Canadian Institute of Assessors (ICE) and the Corporation of Landowners of Quebec (CORPIQ) joined forces to ask the Ministry of Municipal Affairs and Housing (MAMH ) to extend the deadline for filing requests for review on property assessments of the roll 2020-2022.

The group made a submission to this effect to the Ministry, and also issued a press release. These joint actions followed several emails and requests from the president of the AIC-QC, Cynthia Villeneuve, since March 24, 2020 making the request. Mme Villeneuve noted that it is the responsibility of that department to ensure fairness to Quebec taxpayers following the application of a legal restriction from the Government of Quebec by giving additional and acceptable time to assert their rights to dispute property assessments following a return to “normal” business activities. Mme Villeneuve further confirmed that New Brunswick, Ontario, British Columbia and Alberta had already made postponement arrangements to address the current situation. She indicated that AIC-QC hopes to have brought attention and motivation to postpone this deadline while the whole of Quebec has been “put on PAUSE!”

Some media across the province have covered the subject, including La Presse, 1077FM Sherbrooke, CHOI FM 98.1, and many others.

Despite all the efforts to date, this request unfortunately remains unaddressed by the Quebec government.

On February 25, 2020, AIC-Manitoba President, Jason Schellenberg, and President-Elect, Nicholas Ruta, met with Manitoba Finance Minister, the Honourable Scott Fielding.

In addition to introducing AIC-Manitoba and providing an overview of the important role appraisers play in the Manitoba real property landscape, it was an opportunity to discuss AIC-Manitoba’s 2020 pre-budget submission to the Minister.