Why Mortgage Data in Canada Is So Fragmented (And Why That's a Problem)
I spend a lot of time thinking about mortgage data in Canada. Probably more than most people. And the more I dig into how our mortgage market actually works, the more I realize we have a serious problem that almost nobody talks about.
Canada's mortgage market is worth $2.2 trillion. That's not a typo. Two point two trillion dollars. And yet, if you're an investor trying to figure out what's happening in alternative lending, or a PropTech company trying to build something useful, or even a lender trying to benchmark your portfolio... you're basically flying blind.
Here's why.
We Have Too Many Cooks in the Kitchen
Let me walk you through the cast of characters in Canada's mortgage world, because it's honestly kind of ridiculous.
The Big Six Banks control about 67% of all mortgages in Canada. That's RBC, TD, Scotiabank, CIBC, BMO, and National Bank. These guys are federally regulated by OSFI (Office of the Superintendent of Financial Institutions), which means they have to follow strict rules about stress tests, capital requirements, and underwriting standards.
Credit unions and caisses populaires hold another 13% of the market. But here's where it gets messy: most of them are provincially regulated, not federally. That means a credit union in BC follows different rules than one in Ontario. Different reporting requirements, different stress test rules (or sometimes no stress test at all), different everything.
Alternative lenders — this includes mortgage finance companies (MFCs), mortgage investment entities (MIEs), and private lenders — make up the rest. Some are regulated by OSFI. Some are provincially regulated. Some aren't really regulated at all. According to CMHC's data, there are somewhere between 200 and 300 active alternative lenders in Canada right now, holding between $13-14 billion in mortgages. That number grew from around $8-10 billion in 2016.
So we've got:
- Federal regulators (OSFI) watching some lenders
- Provincial regulators watching other lenders
- No regulators watching some lenders
- Different reporting standards for everyone
You see the problem here?
Privacy Laws Make Sharing Data Nearly Impossible
Even if lenders wanted to share data with each other, they'd run into a brick wall called PIPEDA — the Personal Information Protection and Electronic Documents Act.
PIPEDA is Canada's federal privacy law, and it's strict. Really strict. It requires organizations to get explicit consent before collecting, using, or disclosing personal information. And mortgage data? That's about as personal as it gets.
Here's a real example from 2010: the Office of the Privacy Commissioner audited five mortgage brokers and found that none of them fully met their PIPEDA obligations. They were keeping files too long, obtaining credit reports before getting proper consent, and sharing information with lenders without clear authorization.
Since then, the industry has gotten more careful. Which is good for privacy, but it means data sharing is even harder now.
And PIPEDA isn't the only privacy law in play. Quebec has its own privacy law. So does Alberta. And BC. And they're all "substantially similar" to PIPEDA but not identical. So if you're trying to aggregate data from lenders across multiple provinces, you're dealing with multiple legal frameworks.
The result? Every lender sits on their own data, in their own silo, using their own systems, under their own regulatory framework. Nobody shares. Nobody can share. The data stays fragmented.
No Central Data Repository (Unlike the US)
In the United States, the mortgage data problem was solved decades ago.
Black Knight (now owned by ICE) generates $1.4 billion in annual revenue selling mortgage data. CoreLogic does $2.1 billion. ATTOM Data does $150+ million. There are over 30 established mortgage data providers serving every major institution.
These companies can exist because the US has standardized reporting, centralized data sources, and a regulatory environment that allows for (anonymized) data aggregation.
Canada has... CMHC reports. Which come out quarterly. With a several-month delay. And don't cover the entire market.
The Bank of Canada just got access to improved loan-level data in 2024 — but only for federally regulated lenders, which represent about 80% of the market. The other 20%? Still a black box.
CMHC publishes their Residential Mortgage Industry Report a few times a year, and it's honestly the best thing we have. But even CMHC admits they're working with incomplete data. Their Fall 2024 report notes that alternative lender data arrives "several months later" than data from banks, making it hard to get a real-time picture of the market.
The Real-World Impact
This fragmentation isn't just annoying for data nerds like me. It has real consequences:
Alternative lenders can't benchmark themselves. If you're running a private mortgage fund and your 90-day delinquency rate is 2%, is that good or bad? You literally have no idea, because there's no industry benchmark data. (For context, according to CMHC's Fall 2024 report, alternative lenders had a delinquency rate of 1.93% while banks were at 0.25% or lower — but most alternative lenders don't even know these numbers exist.)
Investors are making $100M+ decisions blind. Investment funds allocating capital to mortgage lending have to rely on individual lender data and hope it's accurate. There's no independent verification, no market-wide analytics, no way to stress-test a portfolio against actual market conditions.
PropTech companies can't build useful tools. Want to create a platform that shows borrowers fair market rates for alternative lending based on their profile? Good luck finding the data. Want to build underwriting models trained on Canadian mortgage performance? The data doesn't exist in any usable format.
Even regulators don't have the full picture. OSFI just got better data from federally regulated lenders, but provincial regulators are still working with whatever their jurisdictions provide. There's no unified view of the entire Canadian mortgage market — even for the people whose job is to keep it stable.
Why This Matters Right Now
The fragmentation problem is getting worse, not better, for three reasons:
1. Alternative lending is growing fast. CMHC's data shows alternative lenders grew their outstanding mortgage values faster than traditional lenders in early 2024, despite lending more conservatively than in previous years. That growth means more data is trapped in unregulated or provincially regulated silos.
2. More mortgages are renewing at higher rates. Over 750,000 mortgages will renew in the last half of 2025, followed by another 1.15 million in 2026. Many of these were originated in 2020-2021 at rock-bottom rates. Understanding who's at risk of default requires data we simply don't have access to.
3. Regional markets are diverging. According to recent analysis, Quebec and BC are experiencing different rate environments and credit conditions than Alberta and Saskatchewan. But without good data on each regional market, it's hard to understand what's actually happening on the ground.
What Needs to Happen
Here's what I think would actually fix this:
Anonymize the data properly. PIPEDA allows for anonymized data sharing. Strip out names, addresses, exact property locations — use postal code prefixes, credit score ranges, broad employment categories. It's technically possible to share useful data without violating anyone's privacy.
Create industry standards. Even if lenders can't share data directly, they could all report to a neutral third party using standardized formats. Think of it like how credit bureaus work — everyone reports to Equifax and TransUnion using agreed-upon data formats.
Give smaller players access. Right now, the only entities with decent mortgage data are the big banks (who have their own portfolios) and CMHC (who gets submissions from NHA MBS issuers). Everyone else — the 300+ alternative lenders, the 100+ PropTech companies, the investment funds — they're operating in the dark.
The Bottom Line
Canada's mortgage market is fragmented because we have multiple regulators, strict privacy laws, and no centralized infrastructure for data sharing. Unlike the US, where mortgage data is a multi-billion dollar industry serving thousands of clients, Canada has quarterly CMHC reports and not much else.
This isn't some academic problem. Real money is being mispriced. Real businesses can't get the data they need to operate efficiently. Real borrowers are paying more than they should because lenders can't properly assess risk.
The market is worth $2.2 trillion. It deserves better than spreadsheets and educated guesses.