What an examination is actually testing
A brokerage examination is not a review of your judgement on individual deals. It is a test of whether your records demonstrate that the required steps happened, in the required order, by someone authorised to do them.
That distinction matters, because it changes what you should be building. A brokerage with excellent judgement and thin records fails. A brokerage with ordinary judgement and complete records passes.
Broadly, requests cluster into four areas:
- Licensing and supervision — who was licensed, when, and who supervised them
- Client files — disclosure, suitability rationale, signed documents, identity records
- Anti-money-laundering — identity verification, source of funds, reporting decisions
- Policies and their application — you have a policy, and the files show it being followed
Verify before you act. Regulatory requirements change and vary by province. Confirm anything here with your regulator or your brokerage's compliance counsel before relying on it.
Where files reliably fall apart
Suitability rationale that lives in someone's head
The recommendation is defensible. The record of why it was recommended does not exist. An agent who has left the brokerage cannot explain their reasoning two years later, and nobody else can either.
If a file cannot answer "why this product, for this borrower, at this time" from what is written down, it is incomplete regardless of how good the advice was.
Disclosure that was sent but never evidenced
Disclosures get emailed. The email is in someone's Outlook, not in the file. There is no record of delivery, no acknowledgement, and no version of what was actually sent.
Supervision as an assumption
Policy says the principal broker reviews files. Nothing records that a review happened, who did it, when, or what they found. Supervision that leaves no trace did not happen, as far as an examination is concerned.
Identity records scattered across systems
Identity verification lives in one tool, the deal in another, the notes in a third. Assembling per-file evidence means three exports and manual reconciliation.
The structural fix
The pattern in every one of those failures is the same: the evidence was produced as a by-product of work happening somewhere else, and never attached to the file.
So attach it at the moment of the work:
| Instead of | Do this | |---|---| | Suitability reasoning in conversation | A required field on the deal, captured before it advances | | Disclosure by personal email | Sent from the file, versioned, with delivery and acknowledgement recorded | | Supervision by assumption | An explicit review action, attributed and timestamped | | Identity in a separate tool | Identity records written back onto the deal |
None of this is exotic. It is the difference between a system that records what happened and a system where the record is optional.
What "audit-ready" should mean
The working test: can you produce a complete per-file evidence pack, for any file, without asking a human to go and find things?
If yes, an examination is an export. If no, it is a project — and the project runs on the regulator's timeline, not yours.
That is the bar worth building toward, whatever software you run. In Mortgage360 it is the compliance module, but the principle stands independently of the tool: capture at the point of work, or reconstruct under deadline.