4orm Finance

One duty, six markets, the same shape.

Establish what the person needs, weigh the options, recommend with a reason, disclose what matters, obtain informed consent, and keep a record another qualified person could re-perform. Five of these six markets test exactly that. The sixth tests whether the money stayed put.

Choose a market
Mortgage brokering
First paid market · Ontario
100% of reviewed files

Why this mortgage suited this borrower.

A recommendation can be right and still be impossible to prove. In its targeted review the regulator measured how often the file could not demonstrate the assessment at all, and the answer was every file it selected.

1,162
brokerages
FSRA sector counts
14,585
regulated professionals
FSRA sector counts
270,000
transactions a year
FSRA sector counts
100%
of reviewed files with no documented suitability
FSRA 2025-26

Targeted findings on selected files, not a measure of the whole market

Automotive finance
Ontario, with national transaction volume
Compensation disclosure

What options existed, what was presented, and why this one was selected.

The finance office is where the deal is actually decided, often late in the day and quickly. The regulator has issued guidance on lender submissions, on which offers were presented, and on compensation that was never disclosed.

8,000
dealers
OMVIC and CADA
30,000
registered salespeople
OMVIC and CADA
1.9M
transactions a year, national
OMVIC and CADA
3
things that must be shown: submitted, offered, paid
OMVIC guidance

Counts are firm and office level, never individual practitioner level

Life and health insurance
Ontario
45% failed needs-based sales

Why this product met the needs of this person, and why it was recommended.

Examinations have found missing notes, no disclosure of the range of products available, and no needs analysis on file. The recommendation may have been sound. The evidence that it was is what is absent.

6,680
firms
FSRA sector counts
61,070
regulated professionals
FSRA sector counts
45%
of examined agents failed needs-based sales practices
FSRA
3
gaps found repeatedly: notes, product range, needs analysis
FSRA

Transaction volume is not published for this market

Investments
Dealers and advisers
Recorded without the basis

Why this investment suited the objectives and the risk tolerance of this client.

Know your client, know your product, then a suitability determination that holds. Across 105 firms the regulators found suitability determinations recorded without the basis for them. The conclusion was on the file. The reasoning that produced it was not.

105
firms reviewed, suitability determinations recorded without a basis
CSA and CIRO
3
tests that have to connect: know your client, know your product, suitability
CSA and CIRO
Every
recommendation, order and material change carries the duty
CSA and CIRO

This is the closest market to mortgage. The duty has the same shape, the same three parts and the same failure: the determination survives on the file while the basis for it does not. A firm that carries both, and many do, carries one duty twice.

All figures Canadian dollars

Credit unions
Provincially regulated, member owned
Four duties, one institution

One member, several duties, and a different record for each.

A credit union does not carry one of these duties. It carries most of them at once. A lending decision, an investment recommendation through the wealth arm, an insurance needs analysis, and money laundering obligations across all of it. Each has its own regulator, its own clock and its own idea of what a complete file looks like.

4
duties inside one institution: lending, investments, insurance, money laundering
Duty shape, not a market count
1
member, who does not care which duty applies
 
1
integrity layer across all of them
 

Said honestly, this is a different sale. A credit union buys across lines rather than into one, which means a longer cycle, a committee, and often an existing banking-system vendor in the room. The argument is not that it is quick. It is that a member-owned institution has the strongest reason of anyone here to be able to show why a recommendation suited the member.

No population count is published here because we do not have a verified one

Settlement and client money
Payment providers, crypto asset platforms, stablecoin issuers
A controls question

Not whether the advice was right. Whether the controls happened and the money stayed put.

This is the one market on this page where the test is not suitability. Somebody holds an asset that belongs to somebody else, and has to be able to show, on any past day, that it was all there and that the controls ran. Three regimes, one shape.

745
providers self declaring that they hold end user funds
Management estimate, self declared
3 yrs
between independent reviews, dated from when the duty attached to that firm
RPAR s. 17(1)
$10M
maximum penalty for a very serious violation
Retail Payment Activities Act
2027
expected coming into force of the stablecoin framework
Department of Finance Canada

Payment providers. Every provider holding end user funds owes an independent review at least once every three years. The reviewer may be internal to the firm, so nobody has to be hired. Registration date plus three years is the deadline for that firm, it is per firm and rolling, and no market-wide first review date has been published.

4orm does not do the independent review. 4orm produces the material the review runs on. The regulations disqualify anyone who helped establish or maintain the framework from performing the review, and this platform does exactly that work. The reviewer writes and signs the findings.

Crypto asset trading platforms. Platforms authorized to do business with Canadians hold client assets on terms set in their own authorization, so the custody condition and the reporting obligation differ platform by platform. The published list is the starting point, and each set of terms has to be read on its own.

Stablecoin issuers. Canada has enacted a federal stablecoin framework, with the Bank of Canada administering it and a reserve of high quality liquid assets held against the coins outstanding. It received royal assent on 26 March 2026 and is not yet in force, with the government expecting it to come into force in 2027. Reporting frequency is left to the regulations and has not been set, so nothing here should be planned against a fixed date.

All figures Canadian dollars

Why one platform covers six markets

The duty is the same six steps everywhere it appears.

This is the reason a firm in one market and a firm in another buy the same thing. The vocabulary is local. The obligation underneath is not.

01

Establish the need

What the person is trying to achieve, in their words, before a product is named.

02

Consider the options

What was available, what was weighed, and what was set aside.

03

Recommend with a reason

The reason recorded while it is fresh, not reconstructed afterwards.

04

Disclose what matters

Material risks, conflicts and compensation, in terms the person can act on.

05

Obtain informed consent

An acknowledgement that is dated, attributable and specific to what was disclosed.

06

Keep a re-performable record

A file another qualified person could pick up and reach the same conclusion from.

Real estate carries the same shape and is the seventh market by the same logic. Complaints opened there rose 88 per cent in a single year, to 2,878 in 2025. It is not a tab because it is not where the first paid work is.

Charitable and philanthropic funds are a real fit for the shape but not for this page. A donor-restricted gift is money held for a stated purpose, and proving it was used for that purpose is the same question in a different suit. What is missing is a suitability duty, a regulator examining files, and a compliance budget, so it belongs in a later conversation rather than beside six markets that have all three.