Canada's Cost of Borrowing (Banks) Regulations, explained

Our FCAC explainer covers that regulator's general market-conduct authority over federally regulated banks. This is the specific rule behind it, for a mortgage: a federal disclosure regulation that plays a similar role to TRID on the US side of this Library, built around different specific numbers.

What the regulation requires, and who it actually covers

The Cost of Borrowing (Banks) Regulations (SOR/2001-101), made under the Bank Act, require a bank to give a borrower a written disclosure statement for a mortgage or hypothec credit agreement, containing the specific cost-of-borrowing information the regulations set out, before the borrower is bound to the agreement. This regulation applies specifically to federally regulated banks. A credit union or a provincially regulated lender is instead covered by that province's own cost-of-credit disclosure law — Canada's provinces and territories coordinated the substance of these rules through a formal harmonization agreement on cost-of-credit disclosure, so the underlying protections are broadly similar even though the specific regulation, and the regulator enforcing it, differs by lender type.

The timing rule: 2 clear business days before signing

A bank has to give the borrower its initial disclosure statement no later than 2 clear business days before the borrower enters into the mortgage agreement, or makes any payment (other than a disbursement charge) in relation to it — whichever happens first. A borrower can waive that 2-day window in writing, but only if they've first obtained independent legal advice about the loan — the same "an informed borrower can shorten a mandatory waiting period, but only with a lawyer's involvement" pattern our reverse-mortgage explainer describes for a different transaction entirely.

Renewal disclosure: a separate, later deadline

For a mortgage being renewed on a specified date, the regulations separately require the bank to provide a subsequent disclosure statement at least 21 days before that renewal date. If the agreement is later amended in a way that changes the payment schedule or increases the total cost of borrowing, the bank has to disclose that change within 30 days of the amendment — a distinct, dated deadline from the pre-signing and renewal windows.

How this compares to TRID

Our TRID timeline explainer covers the US equivalent: a Loan Estimate within 3 business days of a completed application, and a Closing Disclosure at least 3 business days before signing. Canada's federal bank-mortgage rule runs on different specific numbers — 2 clear business days before signing, plus a 21-day advance notice before a renewal that TRID has no direct equivalent for — but the underlying idea is the same in both systems: a borrower is legally entitled to see the real numbers with enough lead time to actually review them before being bound.

What to actually check

Ask your bank exactly when you received your written disclosure statement relative to your signing date, and count backward from your closing date to confirm the 2-clear-business-day window was actually met. If your mortgage is being renewed, confirm you received the renewal disclosure at least 21 days before the renewal date — not just a same-day notice folded into other paperwork.

What this page is, and isn't: an explanation of a real federal disclosure regulation, for general understanding — not a claim about any specific bank's or lender's actual disclosure practices, and not part of our published standard or Register, both of which remain United States-only.