Advocacy and Public Policy
The Appraisal Institute of Canada (AIC) is Canada’s leading real property valuation association with over 5,500 Members across the country and around the world. AIC’s Advocacy Committee works to support and promote our Members on a national and provincial level, and advocates for them on issues that impact the valuation profession and the real estate industry.
Syndicated Mortgage Regulations
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.
In March 2018, the Canadian Securities Administrators (CSA – umbrella organization of the country’s provincial securities regulators) published for comment proposed changes to harmonize the regulatory framework for syndicated mortgages in Canada.
On March 15, 2019, the CSA announced that they are implementing most of the new rules that were initially proposed, which includes “introducing a condition that issuers of syndicated mortgages must deliver property appraisals prepared by an independent, qualified appraiser”.
They also announced that revisions were being proposed and are now seeking a second round of feedback. One of the revisions being the following:
“Given the rapid change of the real estate market in some jurisdictions, the proposed revisions include a requirement that a property appraisal take place within six months before an appraisal is delivered to a purchaser.”
This was one of the recommendations the AIC made in its submission to the CSA in June 2018.
To read the CSA’s latest proposals, please click here.
On July 1, 2018, new syndicated mortgages regulations came into force in Ontario that stipulate that an appraisal for a syndicated mortgage (other than a qualified syndicated mortgage) must be prepared by a member of the Appraisal Institute of Canada who is independent and who holds the designation of Accredited Appraiser Canadian Institute. Mortgage brokers must follow this stipulation and use Financial Services Commission of Ontario specific forms that can be viewed here.
As a reminder, these new and expanded requirements for syndicated mortgages forms only a portion of the entire regulation which can be accessed here.
The regulation makes a distinction between two types of syndicated mortgages:
1) “qualified syndicated mortgage” which includes property that is used primarily for residential purposes, includes no more than a total of four units, and if used for both commercial and residential purposes, includes no more than one unit that is used for commercial purposes, and not for incurring debt on construction or development of property.
2) “syndicated mortgage” which is essentially a “non-qualified” syndicated mortgage and is everything other than what is defined under a “qualified syndicated mortgage”. These are specifically for non-residential properties – often larger, mix used types of properties and generally are used in the “pre-construction” phase.
For qualified syndicated mortgages (i.e. those for residential properties), the regulation does not specify any particular appraisal designation so both CRA and AACI members can complete those assignments.
For syndicated mortgages other than qualified syndicated mortgages (i.e. those for non-residential or development properties), the regulation states that an AACI must do these assignments.
For more information on the new regulations, please click here. For questions or comments, please contact us at .
In a previous communique, we informed Members that on March 8, 2018, the Canadian Securities Administrators (CSA – umbrella organization of the country’s provincial securities regulators) published for comment proposed changes to harmonize the regulatory framework for syndicated mortgages in Canada.
Under this proposal, issuers of syndicated mortgages would be required to deliver property appraisals prepared by an independent, qualified appraiser. A copy of the entire proposal can be found here.
As AIC prepared its submission to the CSA, we sought comments from Members. On June 5, 2018, the AIC sent its submission to the CSA and it can be viewed here.
Mortgage Lending Guidelines
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
Over the past few years, the AIC Advocacy team has been calling on the federal government to encourage its provincial counterparts to apply the Office of the Superintendent of Financial Institutions Residential Mortgage Underwriting Practices and Procedures (B-20 Guidelines) and Residential Mortgage Insurance Underwriting Practices and Procedures (B-21 Guidelines) to non-federally regulated financial institutions to ensure consistent lending practices across the country and a more stable marketplace. This includes established appraisal requirements.
During the last year, AIC Provincial Association Advocacy teams have also been encouraging their respective provincial governments to do so. In early February 2018, AIC-Quebec sent a pre-budget submission to the Quebec Finance Minister which included the recommendation to apply the above mentioned guidelines to all provincially regulated financial institutions. On March 15, 2018, the Quebec Financial Institutions Regulator, the Autorité des Marchés Financiers, updated its mortgage lending guideline to reflect the OSFI B-20 guidelines.
AIC Advocacy efforts have contributed to governments applying these guidelines or at the very least giving consideration to applying these guidelines. We will continue to advocate to the federal and provincial governments. For any feedback or questions on this, please don’t hesitate to contact us at
Federal and Provincial Budgets
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.
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.
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.
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.
As you may recall, the AIC has been advocating to both Finance Canada and CMHC that appraisals should be made mandatory as part of the new program.
AIC is pleased to see that the operational policy manual states that appraisals will be required in the following instances:
- In the event of a repayment triggered by the sale of the property, the Incentive amount must be based on the market value of the property at the time of sale, which generally would be supported by the purchase price as stated in the purchase and sale agreement. In the case where the sale is non-arm’s length to the borrower, an independent third-party appraisal performed by an appropriately qualified real estate appraiser must be obtained.
- In the case of an early voluntary repayment, the Incentive amount must be determined using the fair market value of the property. An independent third-party appraisal performed by an appropriately qualified real estate appraiser must be obtained at time of repayment.
- Where the repayment is triggered by the expiry 25 years, the Incentive amount must be determined using the fair market value of the property. An independent third-party appraisal performed by an appropriately qualified real estate appraiser must be obtained at time of repayment.
For more information, please refer to the entirety of the policy manual here: Operational Policy Manual
In June 2019, the House of Commons Standing Committee on Finance invited individuals and organizations to submit their comments for the 2020 Pre-Budget consultation process. The AIC submitted its paper on August 2, 2019, and a copy can be found here.
Federal Finance Minister Bill Morneau launched Pre-Budget Consultations in November 2018. We asked Members to provide their comments to us via the January 2019 communique as we prepared our submission. On January 29, 2019, we sent in our submission that addressed mortgage lending guidelines and home cultivation of cannabis. Click here to view the submission.
On Monday September 24th, 2018 the Appraisal Institute of Canada – BC Association appeared before the BC Legislature’s Select Standing Committee on Finance and Government Services. Remarks and testimony were provided by AIC-BC 1st Vice-President, Terry Dowle. Committee questions focused on secondary lending and data access. Click here to read the testimony. Parliamentary committee appearances are an important means for AIC to advance appraisal industry interests with government.
In early June 2018, the House of Commons Standing Committee on Finance invited individuals and organizations to submit their comments for the 2019 Pre-Budget consultation process. After received feedback and comments from Members, the AIC submitted its paper on August 3, 2018, and a copy can be found HERE.
Federal Finance Minister Morneau launched Pre-Budget Consultations in November 2017. We asked Members to provide their comments to us via the December 1 communique as we prepared our submission. On January 26, 2018, we sent in our submission that addressed OSFI B-20, B-21 Guidelines, Affordable Housing, Financial Literacy, Mandating Valuation Fundamentals for Investment Portfolios that Include Real Estate and Data Access.
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.
Canadians went to the polls on October 21, 2019 and gave a minority mandate to Justin Trudeau and the Liberal Party with 157 seats in the House of Commons. The Conservatives came out with 121 seats, a 21-seat gain from the 2015 election. That result is driven primarily by where the votes were concentrated, with the Conservatives winning by huge margins across the Prairies and the Liberals spreading their support across different regions, with a strong showing in and around Toronto.
The breakdown of seats looks to give the Liberals enough strength that they will not have to establish any formal coalition to govern. It appears that with the expensive toll of the campaign, and limited fundraising, the NDP will have very little incentive to fight another campaign in the near future.
Over the past 40 days campaigns jockeyed for position in 338 ridings from coast-to-coast-to-coast. Parties on the left and the right offered voters starkly different versions of what the future of our country can and should be. Billions of dollars were committed for national programs, millions of Canadians voted, thousands of candidates put their names on the ballot, hundreds of policies were proposed, and dozens of scandals changed the course of the campaign.
The momentum that the Bloc Quebecois had had over the past several weeks resulted in them having the greatest gain this election, with 32 seats. The NDP, despite last minute momentum driven by Jagmeet Singh, fell back to being the fourth largest party in the legislature, with 24 seats.
The main policy areas discussed during the election included climate change, affordability, pharmacare and the economy. In the weeks ahead, Members of Parliament will be sworn in, as well as a new Cabinet chosen by the Prime Minister.
Below are promises from the four major political parties as it relates to appraisal profession. All of the promises should be considered despite the results of the election.
Liberal Party of Canada
- Expand the First-time Home Buyer Incentive for people in Victoria, Vancouver and Toronto. The value of a qualifying home will go from $500,000 to nearly $800,000
- Add a one per cent annual tax on residential properties owned by those who are not Canadians and who do not live in Canada
- Help people buy newly built homes that are certified zero-emissions by giving them a Net Zero Homes Grant of up to $5,000
- Create a low-cost national flood insurance program
- Complete all flood maps in Canada and develop an action plan to assist home owner relocation for those at highest risk or repeat flooding
Conservative Party of Canada
- Increase amortization periods on insured mortgages to 30 years for first-time homebuyers
- Launch inquiry into money laundering in real estate
- Remove stress test for mortgage renewals
New Democratic Party of Canada
- Double the Home Buyer’s tax credit to $1,500 for first time buyers
- Increase amortization periods on insured mortgages to 30 years for first-time homebuyers
- Add $5 billion to spending on affordable housing in first 18 months in office
- Create 500,000 units of quality, affordable housing in the next 10 years
Green Party of Canada
- Cancel the first-time home buyer grant
- Legislate that housing is a legally protected fundamental human right for all Canadians and permanent residents
- Increase the National Housing Co-investment Fund by $750 million for new builds, and the Canada Housing Benefit by $750 million for rent assistance for 125,000 households
Over the last few years, AIC and AIC-Ontario have been working with the Financial Services Commission of Ontario, the Ontario Securities Commission as well as the Ontario Ministry of Finance on regulations around syndicated mortgage investments.
In June 2019, the Financial Services Regulatory Authority of Ontario (FSRAO) assumed the regulatory duties of the Financial Services Commission of Ontario and the Deposit Insurance Corporation of Ontario.
As part of their new structure, FSRAO will have Stakeholder Advisory Committees that are to serve as consultative bodies to the FSRA Board of Directors on FSRA’s priorities, budget and other matters as the Board deems appropriate.
Recently, AIC was informed that our application to be on a committee has been accepted and are formally on a FSRA Stakeholder Advisory Committee.
The Canadian Real Estate Association (CREA) had their annual Political Action Committee (PAC) days in early October 2018 in Ottawa. As in previous years, the AIC attended this event as it is a great opportunity to network with CREA and its Members and to discuss top of mind issues facing the real estate industry. This event also includes speakers from different players within the Parliament Hill scene including Members of Parliament, political journalists and political pundits. It is a great opportunity to hear firsthand about issues at the federal government level and advocate on behalf of the membership.
AIC Meetings with Federal Government
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.
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.
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.
On June 25, 2019, the AIC President, Thomas Fox, Past-President, Peter McLean, and CEO, Keith Lancastle, met with the President and CEO of the Canadian Mortgage and Housing Corporation, and Senior Vice President, Client Solutions, Romy Bowers.
Among the subjects discussed were:
- Important role AIC members play in Canada’s housing market.
- How appraisals should be required in the new First Time Home Buyer Incentive Program. See more details on this program here.
- Prudent mortgage underwriting guidelines being applied across the country that includes the requirement for an appraisal.
- How appraisers can help prevent money laundering in real estate by detecting potential fraudulent activity.
With housing and the real estate market continuing to be a hot topic for Canadians, this was a great opportunity to relay the important role AIC members play in Canada’s housing market.
On February 5th, 2019, the Appraisal Institute of Canada’s advocacy representatives from across the country met with nearly 20 Members of Parliament and federal government officials on Parliament Hill in Ottawa.
This was the second ever AIC Advocacy Day on the Hill where AIC Members met with MPs to introduce AIC and the important role appraisers play in the real estate industry and in the Canadian economy.
It proved to be an excellent opportunity 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 for the protection of the public.
To view pictures from some of the meetings that occurred, please visit our Twitter page @AIC_Canada.
As we informed Members in last month’s communique, the Department of Finance Canada is undertaking a review of the money laundering and terrorist financing legislation and regulations that currently exist. They sought input from organizations in response to a discussion paper they issued that could lead to legislative changes. The paper, which can be accessed here, included sections on “Leveraging Information in the Real Estate Sector” and on “Non-Federally Regulated Mortgage Lenders”.
As appraisers play a key role in the real estate industry, the AIC, with the feedback received by its Members, made a submission and it can be viewed here.
On August 9, 2019, Statistics Canada unveiled a new Housing Statistics Portal that, in their words, offers users a convenient one-stop shop to find all data and products related to housing such as prices, demography, health and wellness, the labour force, construction and the economy.
This new portal will be continually updated as new information becomes available.
On December 1, 2017, the Federal Court of Appeal upheld an April 2016 decision by Canada’s Competition Tribunal that ordered the Toronto Real Estate Board (TREB) to allow its members to share the sales histories of listed properties online.
On December 21, 2017, the Federal Court of Appeal issued an Order directing a stay of the Competition Tribunal’s Order pending the determination of TREB’s application for leave to appeal that order to the Supreme Court of Canada.
Recently, on August 23, 2018, the Supreme Court of Canada announced it had refused to hear the appeal from TREB. Essentially, this means that Greater Toronto Area realtors can now publish home sales data on their websites.
TREB is Canada’s largest real estate board, which represents more than 50,000 Ontario agents.
AIC we will be monitoring and also seeking to ensure that our members continue to be able to access the data they need to do their work.
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 .
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.
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
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.
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.
On November 6, 2019, the Appraisal Institute of Canada – Ontario (AIC-ON) advocacy representatives from across the province met with Ontario Members of Provincial Parliament (MPP) at Queen’s Park in Toronto.
This was the Second Annual Advocacy Day at Queen’s Park for AIC-ON.
Members met with nearly twenty (20) MPPs to introduce AIC-ON and the important role appraisers play in the real estate industry and in the Ontarian economy.
It proved to be an excellent opportunity to get in front of provincial legislators to ensure appraisers are included in discussions related to real estate as well as to create and build on relationships that could be beneficial for AIC-ON Members and the public.
To view pictures from some of the meetings that occurred, please visit our Twitter page @AIC_Canada. As always, you can send your feedback or comments to
It includes amendments to the Development Charges Act and the Planning Act.
Among the changes is the creation of the new community benefits charges authority in the Planning Act that, when in effect, would increase the certainty of development-related costs for community benefits.
The changes to establish the community benefits charges authority have yet to be proclaimed and require enabling regulatory amendments.
A priority area for consultation is the development of percentages on the value of land that would determine the maximum amount of a community benefits charge.
AIC-Ontario was invited to attend this consultation to provide insight and perspective from the valuation space as these regulatory amendments are being developed.
They explained how assessments and valuations are completed for special purpose properties and they were given the opportunity to explain the ethical standards of appraisers.
They also explained that many assessors are AACI and CRA designated appraisers.
Most of the other presenters addressing the proposed changes represented private sector businesses and industry associations, so it was an honour these Members to provide advice from a third party perspective.
Advocacy in Action in New Brunswick!
Recently, in partnership with other real estate associations in British Columbia, AIC-BC offered their expertise and assistance as well as specific recommendations to the Government of BC on how the real estate industry can help tackle money laundering in the BC real estate. The release can be found here.
66 media outlets across the country such as Global, the Toronto Star, CityNews, CBC and others covered the story. In fact, the total online news audience was over 8 million people.
Furthermore, the Government of BC, by way of the Finance Minister and Attorney General, released a statement welcoming the industry’s recommendations and offer to assist the Government in tackling money laundering in real estate. The statement can be found hereand includes this quote:
“The steps being taken by the B.C. Real Estate Association, the Appraisal Institute of Canada, the BC Notaries Association, the Canadian Mortgage Brokers Association and the Real Estate Board of Greater Vancouver are practical and valuable actions that will help guard against criminals using real estate to launder funds. These actions include accepting only verified funds, introducing mandatory anti-money laundering education and making recommendations to government on better information sharing, more engagement with industry and timely and transparent reporting.
“We applaud these industry associations for their work towards stopping money laundering and ensuring public confidence in the real estate industry.”
AIC Members are steadfast in their efforts to flagging and reporting suspicious and fraudulent activity in real estate and AIC, AIC-BC and all other provincial associations will continue to advocate to governments across the country that AIC Members can help.
The Government of Alberta was contemplating establishing a list of professionals who would be permitted to perform reserve fund studies within the Province.
AIC-Alberta made three submissions during the consultation process, including one to the Minister responsible for the regulations, and were invited to attend two roundtable discussions.
These efforts resulted in a positive result for AIC Designated Members in Alberta.
On December 15, 2018, the Government of Alberta released these new regulations and they stipulate the following:
Reserve fund study provider qualifications
21.1(1) In this Part, subject to subsection (2), in respect of the depreciating
property, an individual is not permitted to act as a reserve fund study provider
unless the individual
- a professional engineer,
- a professional technologist,
- a registered architect,
- a licensed real estate appraiser, who is a member of the Appraisal Institute of Canada and holds the designation of Accredited Appraiser Canadian Institute,
- a certified reserve fund planner who is accredited by the Real Estate Institute of Canada, or
- an individual who has successfully completed training recognized by the Director or possesses qualifications that are recognized by the Director,
Only a handful or professionals are listed and it includes AACI Designated Members. These new regulations will be effective as of January 1, 2020.
It is important to note that in all of AIC-Alberta’s efforts, the case was being made to include both CRA and AACI Designated Members.
Efforts will continue to be made so that CRAs can be recognized as a professional by the Director under the Condominium Property Act that can perform reserve fund studies.
This is just another example of how national and provincial advocacy efforts are important to promote and advance the interests of AIC Designated Members.
For more information, please contact us at
On October 24, 2018, the Appraisal Institute of Canada – Ontario (AIC-ON) advocacy representatives from across the province met with Ontario Members of Provincial Parliament (MPP) at Queen’s Park in Toronto. This was the first ever Advocacy Day at Queen’s Park for AIC-ON. Members met with MPPs to introduce AIC-ON and the important role appraisers play in the real estate industry and in the Ontarian economy. It proved to be an excellent opportunity to get in front of provincial legislators to ensure appraisers are included in discussions related to real estate as well as to create relationships that could be beneficial for AIC-ON Members and the public. To view pictures from some of the meetings that occurred, please visit our Twitter page @AIC_Canada. As always, you can send your feedback or comments to .
AIC-Manitoba partnered with WinnipegREALTORS® to examine how new infill developments affect surrounding property values. Often, new infill development proposals are rejected – or met with resistance. By collecting and analysing data surrounding these developments, AIC-Manitoba Members and WinnipegREALTORS® will then be able to provide stakeholders with the information they need to make well-informed decisions regarding infill development within Winnipeg, and create transparency around these development projects. This partnership provides good visibility for AIC and its Members, and it positions them as industry experts and as Canada’s leading real estate valuation professionals.