Updates to APR Inclusion

We’ve recently had communication with FSRA - there have been some open questions to them with regards to APR around legal fees, to get clarity around the language in the act. Now that we’ve received an official response from their team, we’re asking you to update your own records accordingly.

• For “A” and “B” deals for which there’s only lawyer, include that lawyer in the APR

• For Private/MIC deals, always include the lender’s lawyer in the APR

• For Private/MIC deals, only include the borrower’s lawyer (ILA) in the APR if it’s a mortgage over $75,000 (at which point, there are two lawyers required on the transaction) or it’s otherwise a condition of the mortgage.

Please note, this will be going into effect for deals where the disclosure is signed on or after January 22, 2024. If you require any further clarification, don’t hesitate to reach out.