Short answer
No. FINTRAC’s 24-hour rule can aggregate multiple cash transactions that total $10,000 or more, and suspicious-transaction obligations are not limited to a $10,000 threshold. Deliberately splitting transactions can itself create concern.
Why the client is being asked
A client believes several smaller cash deposits will be easier to explain than one large deposit. Instead, the pattern creates more questions and a weaker down-payment trail.
What FINTRAC’s official guidance says
FINTRAC says threshold reports apply when linked cash or virtual-currency receipts total $10,000 or more within a consecutive 24-hour period. Mortgage-sector identity verification for suspicious transactions applies regardless of amount.
What the rule does not mean
An ordinary electronic transfer is not “cash” merely because it moves money, and a transaction below $10,000 is not automatically suspicious. Lender source-of-funds review can still apply regardless of FINTRAC reporting thresholds.
A practical mortgage example
Illustration only: A buyer deposits $4,000, $3,500 and $3,000 in cash on the same day. The total exceeds $10,000 and the pattern does not establish where the funds came from or whether the lender will accept them for down payment.
How to prevent a closing delay
Do not structure deposits. Use traceable banking channels and preserve legitimate receipts, sale records or withdrawal history. If accumulated cash savings are involved, discuss the evidence with the broker well before making an offer.
Questions worth asking
- Is this document required by law, the brokerage, the insurer or the lender?
- What fact is the document intended to verify?
- Is the source, ownership and movement of every material amount clear?
- Are the application, corporate records, tax documents and bank activity consistent?
- What can be prepared now instead of days before closing?
Rajiv’s broker perspective
Compliance questions should be explained, not treated as a paperwork ritual. My role is to collect accurate information, protect the client’s privacy and present a file the lender can understand. FINTRAC does not choose the mortgage product or approve the loan; A, alternative/B, MIC and private lenders still apply their own underwriting. Changing lender type does not remove the need for truthful identity, ownership and source-of-funds evidence.
Related: Mortgage Knowledge Centre · First-Time Buyer Rules · Declined? Start here
Concerned that your funds or business structure may delay closing?
Send Rajiv the transaction timeline and the documents you currently have. He can identify gaps in the mortgage package and explain which questions come from the lender, insurer or compliance process.