If you receive $10,000 or more in cash in a single transaction, you must report it to FINTRAC in a Large Cash Transaction Report (LCTR), and since October 11, 2024 that duty applies to mortgage brokers, agents and administrators too. The report is due within 15 calendar days. Multiple smaller cash receipts can count as one transaction under the 24-hour rule. This guide covers what triggers a report, what to record, how a large deposit in a client's bank statement differs from cash you receive, and how to keep the file clean for an audit.
TL;DR
- An LCTR is required when your brokerage receives $10,000 or more in cash in a single transaction, or in several transactions within 24 consecutive hours that add up to that amount. The report is due within 15 calendar days.
- Cash means Canadian and foreign bank notes and coins. Cheques, money orders and virtual currency are not cash for this purpose.
- A large deposit on a client's bank statement is a different matter. It is not an LCTR event for you, but it does call for a source-of-funds explanation in the file.
- Filing an LCTR is mechanical. Judging whether a transaction is also suspicious is a separate duty, and a Suspicious Transaction Report (STR) is filed on its own.
- Good records made at the time of the transaction protect the brokerage far more than a report filed late.
Table of Contents
- Why mortgage brokers now have to care
- What counts as a large cash transaction
- The 24-hour rule
- Structuring is a red flag, not a loophole
- What you must record and report
- Deadlines and how to submit
- Large deposits in a client's bank statement
- Why an LCTR often leads to closer scrutiny
- Perspective: reporting is a records problem
- A simple cash-handling procedure
- How Autowrite helps with the paperwork
- FAQ
- Sources
Why mortgage brokers now have to care
For years, large cash reporting was something brokers associated with banks and real estate sales representatives. That changed when mortgage administrators, brokers and lenders were brought within the scope of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. According to Fasken, these mortgage sector entities must report single cash transactions of $10,000 or more, unless the amount comes from a financial entity or public body, or from someone acting for one.
In practice, most brokerages rarely handle cash. Clients pay lenders directly, and legal fees and deposits go through lawyers or notaries. But rare is not never. A client walks in with an envelope for an appraisal fee, a brokerage fee or a deposit, and the reporting clock starts. Owners who assume "we don't take cash" without a written policy tend to discover the gap in the middle of an examination.
What counts as a large cash transaction
Per FINTRAC's guidance on reporting large cash transactions, an LCTR is required when you receive $10,000 or more in cash in a single transaction. The amount is measured in Canadian dollars, so foreign cash is converted at the rate you apply and record.
Cash covers:
- Bank of Canada notes and coins
- Foreign currency notes and coins
- Other fiat currency in physical form
It does not cover cheques, money orders, bank drafts or virtual currency. Virtual currency has its own report, the large virtual currency transaction report, which FINTRAC introduced for web submission alongside the LCTR system.
A useful test: did physical currency change hands with your brokerage as the recipient? If yes, and the total reaches $10,000, you have a reporting event. Whether the client calls it a deposit, a fee or a gift makes no difference.
The 24-hour rule
The most common way brokers miss a report is by looking at each payment separately. FINTRAC's 24-hour rule says that two or more cash transactions totalling $10,000 or more within 24 consecutive hours must be treated as a single transaction when they are conducted by or on behalf of the same person, or for the same beneficiary.
Two details trip people up:
- It is a rolling window, not a calendar day. If a client hands over $6,000 at 11:00 PM and another $6,000 at 2:00 AM the next day, the two fall inside 24 hours and together trigger an LCTR, even though the date changed in between. The rule does not reset at midnight.
- It follows the person, not the file. Payments made by a spouse, a parent or a business partner for the same beneficiary can be aggregated.
A worked example: a client pays $4,000 in cash toward fees on Monday at 10:00 AM, $3,500 on Tuesday at 8:00 AM, and $3,000 on Tuesday at 11:00 AM. The first two are 22 hours apart and total $7,500, which is under the threshold. Adding the third payment, the Monday payment is now more than 24 hours behind, but the Tuesday pair plus anything within a rolling 24 hours before the last payment must be checked. Here, the Monday and the 11:00 AM Tuesday payment are 25 hours apart, so the window covering the last payment holds only $6,500. No report. A fourth payment of $3,500 on Tuesday afternoon would put $10,000 inside the window ending then, and the LCTR is due. Keep a running log with exact times so you can show your arithmetic.
Structuring is a red flag, not a loophole
Some clients learn the threshold and keep every payment just under it. That pattern is itself an indicator. FINTRAC's money laundering and terrorist financing indicators are written for reporting entities and treat attempts to avoid reporting as a warning sign. A client who asks you not to file, or who seems to know the thresholds well and arranges payments around them, warrants an immediate compliance review and possibly an STR.
A single indicator does not make a transaction suspicious by itself. FINTRAC expects a holistic assessment: the client's profile, their stated income, the purpose of the funds and the context. If that assessment gives you reasonable grounds to suspect a money laundering or terrorist financing offence, you file an STR. When a suspicious transaction is also a reportable large cash transaction, you submit both reports.
What you must record and report
The LCTR itself asks for details about the transaction and the people involved. The FINTRAC indicators page also sets out what a cash transaction record contains, including the date of receipt, the amount and currency, and any exchange rates used with their source. Expect to gather:
- The date, time and amount of each cash receipt
- The currency, and the exchange rate and its source if it was foreign cash
- The purpose of the transaction and how it relates to the mortgage file
- The identity of the person who handed over the cash, and of anyone on whose behalf they acted
- Your own reporting entity details and the location where the transaction took place
Identity verification
You must verify the identity of the person conducting the transaction. FINTRAC's methods to verify identity call for government-issued photo identification that is authentic, valid and current. A Canadian passport, a permanent resident card or a provincial driver's licence qualifies. Municipal IDs do not. For non-face-to-face verification you need an approved technology that compares the document against security markers or confirms likeness through live video or a quality selfie. We go through the options in our guide to the five FINTRAC client ID methods.
Location identifiers
If you submit in batches, each branch or office needs the location identifier FINTRAC assigned at enrolment. Module 3 of the batch specifications covers the LCTR format. Using the head office number for every agent's transactions is a common error that gets a batch rejected. A brokerage with several offices should keep a simple table of identifiers by location.
Deadlines and how to submit
The LCTR must reach FINTRAC within 15 calendar days of the transaction, as set out in the LCTR guidance. Calendar days include weekends and holidays, so the date to diarize is the receipt date plus 15, not a business-day count. Fifteen days is not a reason to wait. File when the paperwork is complete, while the client and the details are fresh.
Reports go in through FINTRAC's web reporting system, or by batch for larger volumes. Confirm your enrolment and credentials well before you need them. Discovering on day 14 that nobody at the brokerage has an account is a very avoidable problem.
| Item | Rule |
|---|---|
| Threshold | $10,000 or more in cash, single transaction |
| Aggregation | Transactions within 24 consecutive hours, same person or beneficiary |
| Deadline | 15 calendar days from the transaction |
| Not counted as cash | Cheques, money orders, virtual currency |
| Separate report if suspicious | Suspicious Transaction Report |
Large deposits in a client's bank statement
Many readers searching this topic are really asking about something else: a client's bank statement shows a large deposit, and the lender wants an explanation. This is not an LCTR for your brokerage. You did not receive the cash. But it is connected, because the question the lender and your compliance program both ask is the same: where did this money come from?
A sound explanation file for a large deposit usually includes:
- A short signed letter from the client stating the amount, the date, the source and the reason for the deposit
- Evidence matching the letter: a gift letter and the donor's statement for a family gift, a sale agreement and proof of proceeds for the sale of an asset, a bonus or severance statement from the employer, or a prior statement showing the funds moving between the client's own accounts
- Statements covering the period before and after, so the movement is traceable
- Your own note on how you assessed whether the explanation fits the client's income and profile
A letter that says only "this is savings" rarely survives scrutiny. The more specific and documented the story, the better. Keep the reasoning on file, not just the paper.
If a client cannot or will not explain a large cash deposit, or the story shifts, that is an indicator. Do not wait for the lender to ask. Our overview of anti-money laundering mortgage compliance explains where this fits in a brokerage's wider program.
Why an LCTR often leads to closer scrutiny
Filing an LCTR is an administrative event. It does not accuse anyone of anything. But it does put the client on the radar, both for FINTRAC and for your own monitoring. Later transactions by the same client deserve a more careful look, including whether activity matches their declared income. The practical lesson is to document the source of funds at the moment you receive the cash, not months later when someone asks.
FINTRAC's own guidance points to the same habit: record the why behind a transaction, and the context around the client's financial profile. That context is what shows an examiner you were paying attention.
Perspective: reporting is a records problem
We build for Canadian brokers, and what we see is that large cash reporting rarely fails at the filing step. It fails earlier, in the file. The time of the second payment is not written down. The ID was checked but a copy was not kept. The gift letter is in an email thread and the donor's statement is in a text message. By the time the 15 days are close, someone is reconstructing events from memory.
That is why we think of compliance as document intelligence rather than a form to complete. If every document that enters the file is classified, its data extracted and its source tied to the client and the date, then questions such as "what else came in within 24 hours?" or "what is the evidence behind this deposit?" take minutes to answer. Autowrite is designed around that: intake, classification, extraction, and assembling compliance packages in one place, with Canadian data residency. For the retention side, see our note on FINTRAC's five-year rule versus FSRA's six-year rule.
The decision about whether to report, and whether something is suspicious, always stays with the licensed professional and the brokerage's compliance officer. Software should make that decision easier to defend, not make it for you.
— Anant Bawa
A simple cash-handling procedure
Write this down, train everyone, and keep it with your compliance program.
- Decide your policy. Many brokerages choose not to accept cash at all. If that is your rule, say so in writing and tell clients up front. If you do accept it, set who may receive it and where it is recorded.
- Log every receipt immediately. Date, exact time, amount, currency, who handed it over, who received it.
- Check the 24-hour window against the log, for the same person and the same beneficiary.
- Verify identity using an accepted method and keep the record.
- Record the source of funds and purpose in the client's words, then test it against their income and profile.
- File the LCTR inside 15 calendar days if the threshold is met. Diarize the date on the day of receipt.
- Assess for suspicion separately. If the indicators add up to reasonable grounds to suspect, file an STR as well.
- Retain the records for the required period and keep them retrievable. Our guide to audit-ready digital compliance records covers how to organize them.
Ontario brokers should also keep provincial expectations in mind alongside federal rules; see our summary of what FSRA expects on file. Brokers in British Columbia, Alberta and Quebec face the same federal FINTRAC duties, with provincial regulators layered on top.
How Autowrite helps with the paperwork
Autowrite is an AI-powered operating system for Canadian mortgage brokers. It handles document intake, classification and data extraction, syncs with mortgage software, and assembles e-sign and compliance packages, so the evidence behind a large deposit or a cash receipt sits with the right client file. Plans start at $99 per month for Starter, with Pro at $199 per month and Legend at $399 per month, and each comes with a 14-day free trial. See the Autowrite pricing page for the full list, or read how we approach mortgage compliance automation before you try it.
FAQ
Do mortgage brokers in Canada have to file large cash transaction reports?
Yes. Mortgage administrators, brokers and lenders became reporting entities under the PCMLTFA on October 11, 2024, and must report single cash transactions of $10,000 or more, with limited exceptions such as amounts received from a financial entity or public body. If your brokerage never accepts cash, you may never file one, but you still need a written policy.
Does a cheque or bank draft over $10,000 trigger an LCTR?
No. FINTRAC defines cash as physical notes and coins, and cheques, money orders and virtual currency are not cash for this report. A large cheque can still raise source-of-funds questions, and other reporting duties may apply, so assess it on its own facts.
How long do I have to submit the report?
You have 15 calendar days from the transaction. That count includes weekends and holidays. If several payments were combined under the 24-hour rule, count from the transaction that brought the total to $10,000.
Do I need a letter of explanation for a large deposit?
For a deposit in a client's bank statement, lenders commonly ask for one, and your own compliance file should hold one in any case. Make it specific: amount, date, source and supporting documents such as a gift letter, a sale agreement or an employer statement. A vague letter invites more questions rather than answering them.
What if the client asks me not to file?
Do not agree. A request to avoid reporting, or payments kept under the threshold on purpose, are recognized money laundering indicators. Tell your compliance officer, document what was said, and assess whether a Suspicious Transaction Report is also needed.
Sources
- Reporting large cash transactions to FINTRAC
- Reporting transactions to FINTRAC: The 24-hour rule
- Methods to verify the identity of persons and entities
- Money laundering and terrorist financing indicators, financial entities
- Reporting suspicious transactions to FINTRAC
- Module 3: Large Cash Transaction Report specifications
- New Anti-Money Laundering Requirements for Mortgage Administrators, Mortgage Brokers and Mortgage Lenders