The Financial Services Regulatory Authority of Ontario (FSRA) has imposed administrative penalties on S.O.R.A Real Estate & Insurance Ltd., operating as MIC Financial, totaling $150,000, and a further $10,000 penalty on Roberto Gabriel Mammone, following a settlement with the regulator.
FSRA found that MIC Financial contravened the Mortgage Brokerages, Lenders and Administrators Act, 2006 and its regulations in two respects: by allowing an individual to deal or trade in mortgages on its behalf when it knew, or reasonably ought to have known, that the individual was a broker or agent authorized to deal or trade in mortgages on behalf of another brokerage, contrary to section 43(2) of Ontario Regulation 188/08, and by paying a fee or other remuneration to that individual for dealing or trading in mortgages on its behalf under the same circumstances, contrary to section 44(2) of the same regulation.
Mammone was found to have contravened the Act by doing or omitting to do anything that might reasonably be expected to result in the brokerage failing to comply with its requirements, contrary to section 3 of Ontario Regulation 187/08.
The settlement marks a substantial reduction from FSRA's original enforcement position. In April 2025, FSRA issued a notice of proposal seeking two administrative penalties totaling $300,000 against MIC Financial and a $20,000 penalty against Mammone, alleging the same underlying conduct.
Both parties requested a hearing before the Financial Services Tribunal at that time.
Under the settlement reached more than a year later, the total penalties were reduced by half, to $150,000 for MIC Financial and $10,000 for Mammone, a pattern consistent with FSRA's stated practice of allowing final settlement orders to differ from the sanctions originally proposed.
The case also highlights a coverage distinction insurance professionals working with mortgage brokerages should keep in mind.
FSRA requires every licensed mortgage brokerage and administrator in Ontario to carry errors and omissions insurance approved by the regulator, with minimum limits of $500,000 per occurrence and $1 million in aggregate annually, and extended coverage for fraudulent acts.
Critically, FSRA guidance specifies that E&O insurance held under the Registered Insurance Brokers Act or the Insurance Act, such as coverage carried by an individual or firm in their capacity as an insurance broker or agent, does not extend to mortgage brokering or administration activities.
For entities like S.O.R.A Real Estate & Insurance Ltd. that operate across real estate, insurance and mortgage brokering under one umbrella, that distinction means separate, purpose-specific E&O coverage is required for the mortgage brokering side of the business, a detail brokers placing coverage for multi-licensed firms need to get right.
The case lands amid a marked increase in FSRA's overall enforcement activity across the sectors it regulates, including mortgage brokering and insurance.
According to the regulator's first Enforcement Annual Report, FSRA initiated 100 enforcement actions in the 2024-25 fiscal year, up from 65 the year before. In the life and health insurance sector specifically, FSRA imposed 27 sanctions in 2024-25, including 16 license sanctions and six administrative monetary penalties totaling $232,000, up from 15 sanctions the prior year.
Elissa Sinha, FSRA's director of litigation and enforcement, has said the regulator is committed to enforcement that is "both fair and proportionate" across its regulated sectors.
