A mortgage broker you send business to offers you a pair of tickets. You have not accepted, nothing has been paid, and you have not decided. Your disclosure obligation has already started. RECO's trigger is "as soon as possible after the agent knows, or ought to know" that a benefit might be received - the possibility, not the payment - and event tickets are on its own list of what counts.
This is the section where the gap between what agents think is disclosable and what actually is runs widest. Below is RECO's Bulletin 3.3 on financial benefits and Bulletin 3.4 on your own trades, read on September 19, 2026.
A benefit is not only money
The obligation covers any direct or indirect benefit you or a related person might receive beyond your normal remuneration from the client. RECO's examples:
- payments
- gifts
- event tickets
- promised future services from a third party
So the referral cheque from a mortgage broker is obvious and mostly gets disclosed. The gift basket, the tickets, and the stager who says she will do your next listing for free because you keep sending her work - those are the same category and almost never make it into writing.
"Related person" matters too. A benefit flowing to your spouse, or to a company you are connected to, is still disclosable, and the disclosure has to explain how you are connected to them.
What the disclosure has to contain
Not a sentence saying a referral fee exists. RECO wants the disclosure to answer:
- what the benefit is
- an estimate of its value, or the dollar amount that might be received
- any conditions affecting whether you receive it
- whether it goes to you or to a related person
- how you are connected to that related person
- the relationship between whoever is providing it and you or that person
The value estimate is the one people resist, because a referral fee is often a percentage of something not yet known. An estimate is still required; "an amount to be determined" is not one.
It goes to the client you are providing services to, in writing. You then make best efforts to obtain a written acknowledgement, and if you get one, you give them a copy of it.
The clock starts before the money does
Read the trigger again: as soon as possible after you know, or ought to know, that a benefit might be received.
Two consequences. First, "might" means an arrangement you have not taken up yet is already disclosable. Second, "ought to know" means not having asked is not a defence. If everyone in your office knows that a particular inspector sends something at Christmas, you ought to know.
An agent who discloses when the money lands is not early, on time, or slightly late. They are late by however long the arrangement existed.
Only your brokerage pays you
Separate from disclosure, and absolute: you cannot accept payment directly from a source other than your employing brokerage.
So a referral fee does not get paid to you. It gets paid to the brokerage, which pays you. An arrangement where a third party sends money straight to an agent is a problem no disclosure fixes, and the fact that everyone involved was comfortable with it is not relevant.
Your own deals are a different animal
Buying or selling for yourself changes the obligations rather than removing them. Before any offer is made or received, you have to give all parties written notice of:
- that you are a salesperson or broker
- every fact within your knowledge that affects or will affect the value of the property
- any plan to sell, lease or otherwise dispose of your interest afterwards
With written acknowledgement from each party. That middle item is broader than most people read it: it is not material facts about the building alone, it is anything you know that bears on value. If you are buying because you know the assembly next door is going ahead, that is within your knowledge and it affects value.
The third item is the flip disclosure. Buying with a plan to resell means saying so before the offer, not after it firms.
You cannot act in your own trade
This is the hard stop, and it catches agents who invest. RECO's position is that an agent must not represent a party to their own personal trade, because the conflict of interest is too severe to manage.
Not disclose and proceed with consent. Cannot act. If you are the buyer, you are the buyer, and the other side needs someone who is not you.
An interest in a property you are listing
The related case is where you hold an interest in a property while representing a client in a trade on it. There the disclosure describes the nature of the interest with enough detail that the reader understands the conflict or potential conflict, and it goes to your client and every person making or receiving an offer - not your client alone.
Timing is the same shape as the rest: as soon as you know or ought to know, and before any offer is made. Written, with best efforts to obtain an acknowledgement and a copy provided.
What to do this week
List every arrangement you currently have. Mortgage brokers, lawyers, inspectors, stagers, contractors, moving companies. Note which ones have ever sent you anything, including at Christmas. That list is your disclosure surface, and most agents have never written it down.
Put a number against each one. The disclosure needs an estimate of value. Working it out once, calmly, is easier than improvising it inside a transaction.
Check the payment path. If anything has ever been paid to you rather than through your brokerage, that is the item to raise with your broker of record this week rather than next year.
If you own investment property, plan the representation now. You cannot act in your own trade, so the time to work out who does is before you find the property, not during the offer.
Frequently asked questions
Do I have to disclose a referral fee I have not received yet? Yes. The trigger is knowing, or having reason to know, that a benefit might be received - not receiving it. An arrangement you have not taken up is already disclosable.
Are gifts and event tickets really financial benefits? Yes. RECO's own examples are payments, gifts, event tickets and promised future services from a third party. The non-cash ones are the ones that go undisclosed.
What if the benefit goes to my spouse rather than me? It is still disclosable. The disclosure has to say whether you or a related person receives it, and explain how you are connected to that person.
Can a mortgage broker pay me directly? No. You cannot accept payment from a source other than your employing brokerage. The payment goes to the brokerage, and the brokerage pays you.
How precise does the value estimate have to be? It has to be an estimate of the value or the dollar amount that might be received, together with any conditions affecting whether you get it. A percentage with no number attached leaves the client unable to see what is at stake, which is what the disclosure exists to show.
Can I represent the buyer when I am the one selling? No. An agent must not represent a party to their own personal trade; RECO treats the conflict as too severe to manage rather than as something consent can cure.
When do I disclose on my own purchase? Before any offer is made or received, in writing, with a written acknowledgement from each party - covering that you are registered, every fact you know that affects value, and any plan to dispose of your interest later.
Where is the authoritative version? RECO's Bulletin 3.3 and Bulletin 3.4. Bulletins explain duties under TRESA and its regulations rather than creating them, and they are revised. This is a practice summary, not legal or tax advice.
The whole map is in our plain-English index of every RECO bulletin. The neighbouring sections worth reading are dealing with a self-represented party and the advertising rules.