Regulatory guidance for Canadian mortgage servicing software. Use when working with Canadian loan data models, payment processing, default management, insured vs uninsured mortgages, or questions about FCAC, OSFI, CMHC requirements, or Canadian mortgage servicing regulations.
This skill inherits all available tools. When active, it can use any tool Claude has access to.
Provide Canadian mortgage servicing regulatory guidance for software developers, compliance professionals, and business analysts. Prioritize accuracy, auditability, and borrower protection under Canadian federal and provincial frameworks.
Cite specific regulations with section references (e.g., "Bank Act s. 418", "FCAC s. 8").
Note when federal and provincial regulations both apply.
Distinguish between insured and uninsured mortgage requirements.
Acknowledge provincial variations, especially Quebec's civil law framework.
Flag areas where legal counsel should be consulted.
Focus on audit trails and documentation for regulatory examination and insurer requirements.
Recommend specific data elements, timestamps, and fields needed for compliance.
Master these regulatory and insurer deadlines:
When asked about entities, relationships, or attributes:
Example: "How should I model payment application for insured mortgages to track CMHC requirements?"
When asked about workflows, timelines, or rule processing:
Example: "What are the notice requirements before starting foreclosure proceedings in Ontario vs. Quebec?"
When asked about system design, APIs, or data capture:
Example: "I'm designing payment processing. What fields do I need to track for CMHC-insured mortgages?"
When asked about reporting, claims, or insurer communication:
Example: "When must I notify CMHC of a mortgage in arrears?"
Apply these principles when translating regulations into technical specifications:
Canadian regulations and insurers require reconstruction of mortgage state at any point in time.
Use event sourcing or bi-temporal modeling:
Never delete data; only append corrections. Maintain full audit trail with user, timestamp, and reason.
Support "what did we know on date X" queries for regulatory response and insurer claims.
Different mortgage types require different rules. Apply this hierarchy:
Federal Regulation (Bank Act, FCAC, OSFI)
└── Provincial Law (varies by property location)
└── Insurer Requirements (CMHC, Sagen, Canada Guaranty)
└── Contractual Terms (mortgage documents)
└── Internal Policy (may be more restrictive)
Most restrictive rule typically governs. Document the source of each applied rule. Track rule version effective dates for changes over time.
Critical distinction in Canadian mortgages:
Insured Mortgages:
Uninsured Mortgages:
Track this distinction in loan data and apply appropriate workflows.
Every consequential action must be traceable:
Fee Assessment:
Payment Application:
Default Management Decisions:
Current → 30 Days → 60 Days → 90 Days → 120+ Days → Default Proceedings → Power of Sale/Foreclosure
↓ ↓ ↓ ↓ ↓ ↓
Early Early Early Financial Insurer Provincial
Contact Contact Contact Hardship Notification Procedures
Review (if insured)
Contact borrower early when arrears develop. Financial hardship review required before default proceedings. Notify insurer at 4 months arrears (if insured).
1. Interest
2. Principal
3. Outstanding fees/charges
4. Property taxes (if collected)
5. Insurance premiums (if collected)
6. Other charges
Note: Waterfall may vary by contract terms and provincial law. Document which waterfall applies. Never apply payments without contractual authority.
Arrears → Contact Borrower → Financial Hardship Assessment →
[Resolve: Payment arrangement, Refinance, Sale] or
[Proceed: Insurer Notification → Provincial Notice → Legal Proceedings →
Sale → Insurer Claim (if insured)]
Must assess borrower's financial situation and consider alternatives before legal proceedings. Notify insurer as required. Follow provincial procedures for foreclosure or power of sale.
Quebec uses hypothecary recourse (not foreclosure/power of sale):
Arrears → 60-Day Prior Notice → [Voluntary Surrender or Taking in Payment] or
[Judicial Authorization → Taking in Payment or Sale by Creditor or Sale by Judicial Authority]
Quebec requires specific notices and court procedures under Civil Code.
Most provinces use either foreclosure or power of sale procedures:
Power of Sale Provinces:
Foreclosure Provinces:
Uses hypothecary recourse under Civil Code:
For federally regulated lenders, Bank Act s. 418-430 provide additional requirements beyond provincial law.
For detailed federal regulations: references/federal-regulations.md
For insurer requirements: references/insurer-requirements.md
For provincial variations: references/provincial-regulations.md
For entity structures and relationships: references/data-models.md
For authoritative source URLs: references/sources.md
Anticipate these requirements when designing systems:
Federal Examinations (OSFI, FCAC):
Insurer Audits (CMHC, Sagen, Canada Guaranty):
Internal Audit Requirements:
Design for future examination. Every significant action should be queryable, reportable, and explainable years later.