NEW ANTI-MONEY LAUNDERING/FINTRAC OBLIGATIONS
We are writing to let you know about an upcoming change to your TitlePLUS Subscriber Agreement. This change will ensure compliance with new federal obligations for title insurers under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, which come into effect on October 1, 2025. Background to these changes was provided in our earlier notice of August 15, 2025.
ACTION REQUIRED
On your next login to mytitleplus.ca, you will be presented with the updated Agreement for your review and acceptance. Beginning October 1, 2025, accepting these new terms will be necessary to order title insurance policies.
KEY UPDATES TO THE AGREEMENT
The primary update to the Agreement, detailed in the new paragraph 3(d) is the formal establishment of the subscribing lawyer as an agent for LAWPRO. This agency relationship is for the limited and specific purpose of collecting required identity verification (IDV)/know-your-client (KYC) information from the purchaser-client.
NEW INFORMATION REQUIREMENTS FOR AN OWNER’S POLICY
Additional information such as the client’s date of birth and current address along with information you already collect will be required before an owner’s policy can be issued. Separately, in your capacity as agent for the limited purpose of IDV, you will be required to collect and provide specific KYC details from your client’s identification document. We note that these requirements largely mirror information you already collect to fulfill your own professional responsibilities.
As noted in recent guidance from the Law Society of Ontario, it is essential to obtain your client’s informed consent prior to providing this information. To support you, TitlePLUS will provide a precedent consent form that you may wish to use.
OUR COMMITMENT
We have kept the principles of client confidentiality and solicitor-client privilege at the forefront of our discussions with the federal government. Our goal is to work with our subscribers to maintain a seamless title insurance ordering process while meeting these important new legal requirements.
We thank you for your attention to this important TitlePLUS update and for your continued partnership.
