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Receipt of funds records are not wire confirmations alone

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Receipt of funds records are not wire confirmations alone

Buyer sends Interac screenshot. Agent forwards to lawyer. Brokerage compliance asks for source-of-funds file six months later — agent has pixelated PNG, no ledger, no linkage to buyer ID.

Direct answer

Under FINTRAC guidance, a receipt of funds record is generally required when a real estate broker or sales representative receives funds in any amount — with exceptions such as funds received from a financial entity or public body. The record has prescribed contents (date, amount and method of receipt, currency, payer identity details, affected account numbers and holders, other involved parties, reference numbers, purpose of the transaction), plus a copy of the power-to-bind provisions from corporate records when the payer is a corporation. Retention per FINTRAC guidance: at least five years from record creation. Retain this on checklist lines, not single wire screenshots. Not legal advice — your compliance officer interprets when and how the obligation applies. See beneficial ownership records.

Two nuances worth flagging to compliance (both from FINTRAC guidance — confirm current wording): when two represented parties are in a deal and one side receives funds from the other side's client, it is the representative of the paying client who keeps the receipt of funds record; and a separate large cash transaction record applies to receiving $10,000 or more in cash.

Typical retention lines

MilestoneCommon docs
Initial depositReceipt of funds details, confirmation, payer ID link
Additional fundsUpdated confirmations per tranche
Source of fundsSupporting docs per brokerage policy
Third-party fundsGift letter, donor ID per policy
Corporate payerPower-to-bind excerpt from corporate records

GTA pre-con and assignment deals add schedule complexity — separate lines per deposit tranche.

Workflow

  1. Funds checklist at offer — parallel to buyer onboarding.
  2. Guest link for buyer upload of bank letters — QC legibility.
  3. Reject screenshot-only when policy requires statement PDF.
  4. Export at closing to brokerage archive + deal room.
  5. Co-agent compliance review before firm if policy requires.

Related: new construction buyer intake, brokerage compliance records.

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General information only. Not legal, tax, or FINTRAC advice. Hivi-X is document-collection software — not a licensed real estate brokerage. Not affiliated with or endorsed by RECO, TRREB, or FINTRAC. Verify obligations against current FINTRAC guidance and your brokerage compliance officer.

Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.

Frequently asked questions

When is a receipt of funds record required?
Per FINTRAC guidance, generally whenever a real estate broker or sales representative receives funds in any amount — with exceptions, such as funds received from a financial entity or public body. Your compliance officer interprets when the obligation applies to your file.
What does a receipt of funds record contain?
FINTRAC guidance lists prescribed contents: date of receipt, amount and method, currency, the payer's name/address/date of birth and occupation or principal business (or entity details), affected account numbers and holders, other involved parties, connected reference numbers, and the purpose of the transaction. Verify the current list against FINTRAC guidance.
Is a wire screenshot enough?
Often not alone — the record has prescribed fields a screenshot rarely covers, and brokerage policy may require additional source-of-funds documentation. QC completeness on checklist, not single screenshot theatre.
How long are these records kept?
FINTRAC guidance states at least five years from the date the record was created. Confirm with your compliance officer.
What about large cash amounts?
FINTRAC has a separate large cash transaction record and reporting obligation for receiving $10,000 or more in cash — follow your brokerage compliance manual; this page does not cover reporting.
Does Hivi-X interpret FINTRAC?
No. Document collection structure only.

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FINTRAC Receipt of Funds Record Keeping | hivi-x Docs