Client Information Records - Individuals

For most builders, the FINTRAC requirements are almost identical to current practice. 

Bottom Line Tip:

FINTRAC has said you don’t need to keep client information on a separate form unless you want to. It may be easiest to simply add lines for date of birth and occupation to your Offers, and keep a photocopy of all buyers’ passport ID pages, driver’s license, or equivalent government-issued documents.

What do you have to do?

• Record buyer’s name, address, date of birth and occupation.
• Make sure they have original government-issued ID that has not expired, showing the same name and address they gave you. Click here to see the list of acceptable identification.
• Photocopy or record the number, type of document, and where it was issued.
• If the buyers are not physically present, you will need two pieces of acceptable documentation for each person. These can include notarized photocopies of original documents, credit reports, etc. Click here for more details.
• If the property is being bought by more than one person, do this for all buyers.

When do you have to do it?

• When you enter into the transaction. In virtually all cases for builders who come under the FINTRAC requirements  this will be when the Offer to Purchase is signed.

How do you have to record the information?

• As long as the information is in your files and can be made available to FINTRAC investigators if they need it, that is fine.

How long do you have to keep it?

• Five years from the completion of the transaction.

What if you can’t get the information?

People should be quite willing to give you the information FINTRAC requires. Sometimes, you may find someone who refuses to give their date of birth. If so, record that on the file (and their reasons if they give any). 

Client Identification Record Checklist - Individuals 

Click here for a checklist of main requirements for a client identification and verification record for individuals.

Special Cases

If a buyer is not in Canada, see Foreign buyers.

If a buyer is acting for a third party, see Buyers who are purchasing for someone else.

Acceptable documents

Acceptable documents for identification of a person must have a unique identifying number and be issued by a provincial, territorial or federal government (or foreign equivalent). The document has to be valid and cannot have expired.

This can include:

• birth certificate  (except birth or baptismal certificates issued by a church rather than a government body)
• driver’s licence
• provincial health insurance card (except in Ontario, Manitoba or Prince Edward Island where it’s illegal to use health cards for identification); in Quebec, you cannot ask for a person’s health card but can accept it if the person wants to use it for identification
• passport
• record of landing
• permanent resident card
• certificate of Indian status
• provincial or territorial identification card issued by any of the following or their successors:
  • the Insurance Corporation of British Columbia
  • Alberta Registries
  • Saskatchewan Government Insurance
  • the Department of Service Nova Scotia and Municipal Relations
  • the Department of Transportation and Public Works of the Province of Prince Edward Island
  • Service New Brunswick
  • the Department of Government Services and Lands of the Province of Newfoundland and Labrador
  • the Department of Transportation of the Northwest Territories, or
  • the Department of Community Government and Transportation of the Territory of Nunavut
• other similar document

An employee identification card issued by an employer is not acceptable, even when the employer is a government department or agency.

NB: If your buyer wants to use his or her Social Insurance Number (SIN) for identification, that is acceptable, but the number itself must not be given to FINTRAC on any type of report. Instead, note on your records that the SIN card was presented and matched the person’s name.